Preface

OSHA

Compliance

Guide

Regulations • Sample Plans • Forms

H. Ray Kirk

Charles B. Lewis

Attorney at Law

Editor

© 1992 - 1999 by Summers Press, Inc.

© 2000 - 2002 by Summers Press, a division of Aspen Publishers, Inc.

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Preface

The goal of this book is to help provide employers with the knowledge and the framework for a safer work environment.

America has more than 6 million workplaces and 93 million workers. In a typical day, 17 workers suffer fatal on-the-job injuries, 137 more die of occupational illnesses, and 17,138 are hurt at work. Besides the human suffering, workplace accidents cost the U.S. economy more than $110 billion each year.

Compliance with OSHA's standards alone will not prevent all injuries and illnesses. In fact, OSHA standards provide minimum levels of protection. Compliance with the law and with OSHA standards is important, yet an effective plan will look beyond the law and seek to prevent injuries and illnesses, even if compliance is not at issue. Progressive companies have realized that they can minimize workplace injuries and illnesses by implementing comprehensive safety and health management systems that go beyond the regulatory requirements.

Companies with comprehensive safety programs experience lost workday rates that are 60% to 80% below their competitors. They also experience reduced absenteeism and turnover, improved productivity, and lower workers' compensation costs. Effective safety and health management is not only the right thing to do, it also directly benefits the company's bottom line profits.

Every employer should develop and maintain a general safety plan that includes policies, procedures, and practices that protect employees from safety and health hazards. The safety plan should provide for the identification, evaluation, and prevention of general workplace hazards. The plan also should list specific and potential job hazards.

The length of a written plan is less important than how effective it is in practice. As the size of the workforce increases, the need for a written plan increases. The plan should list priorities as well as policies, and provide for a consistent and fair application of rules.

The Digest of general industry safety and health standards contained in this book was designed to aid employers and safety personnel in understanding OSHA standards. A separate chapter provides information on OSHA's basic training requirements.

This book contains:

•	Those standards most frequently overlooked and violated by employers

•	Checklists to help employers inspect a business for compliance with OSHA standards

•	Sample safety plans to help employers implement OSHA standards

Is the information up-to-date?

The OSHA Compliance Guide is updated yearly and may be supplemented more often if required by major changes in regulations. Each year's supplement is designed to keep the Guide current. However, regulations change constantly, and readers are always well-advised to look into whether a regulation has changed since the last publication of the book.

In order to incorporate updated pages easily, the book is published in a three-ring notebook. Throughout the year, we publish minor changes to all our books via our Internet site at www.summerspress.com. We also publish a monthly newsletter through our Internet site that summarizes many of the major regulatory developments involving health and safety issues, as well as developments in the employment law area. Simply choose the Legal News button.

You will automatically receive each update. Like all Summers Press publications, the update includes a 30-day, risk-free review period. If you feel a supplement does not keep your book comprehensive and current, simply return it with no further obligation. The price of an update may vary, but it is always a fraction of the cost of replacing the entire book (as is necessary with most paperback publications).

The OSHA Compliance Guide is, and will continue to be, one of the most current guides of its kind available anywhere in the nation.

H. Ray Kirk, Ph.D.

About the Author

H. Ray Kirk, Ph.D., is a nationally renowned speaker and has conducted over 950 seminars on OSHA and hazardous waste laws. He has conducted seminars for the following organizations: Mississippi Manufacturers Association, Chevron, Exxon, B.F.I., Waste Management, B.A.S.F., World Colorpress, and Rubbermaid. He also has conducted seminars for the Army, Navy, Air Force, Marines, National Guard, and Air National Guard. Mr. Kirk is listed in Who's Who in Environmental Training.

Mr. Kirk has been involved with EPA and OSHA regulations since 1975 and has managed hazardous waste treatment, storage, and disposal facilities in Massachusetts, Ohio, Florida, and Louisiana.

He has received a number of environmental certifications, including:

•	Certified Environmental Specialist (CES) by the Environmental Assessment Associates

•	Certified Trainer (CT) by the National Environmental Training Association

•	Certified Environmental Compliance Officer (CECO) by the U.S. Army

Mr. Kirk received his Ph.D. in crisis management. He can be reached at Occupational Safety Health Inspections, Inc. (OSHI), a consulting firm specializing in OSHA and EPA compliance at 888-561-2498, Internet site at http://www.oshi-inc.com, or e-mail address rkirk@oshi-inc.com.

H. Ray Kirk is also the author of:

•	California OSHA Compliance Guide

•	EPA Compliance Guide for Hazardous Waste

•	Automotive Workplace Guide to EPA and OSHA

•	OSHA Guide for the Construction Industry

•	OSHA Training Guide

•	California OSHA Training Guide

•	California OSHA Training Guide, Spanish Handouts and Tests

•	California OSHA Guide for the Construction Industry

All of these titles are published by Summers Press.

About the Editor

The 2002 update to the OSHA Compliance Guide was edited by Charles B. Lewis, a Managing Editor for Summers Press. He received his law degree from the University of Texas, where he was on the Texas Law Review. He is licensed to practice law in the State of Texas and actively practiced civil trial and appellate law for more than six years. He is the author of Workers' Compensation Law and Strategy Guide, first published by Summers Press in 1997. He also holds a master's degree in creative writing from the University of Houston.

Dear Customer,

As the author of the OSHA Compliance Guide, I would like to personally thank you for your purchase. I am sure you will find this book easy to use and indispensable to your everyday business.

One of the many benefits you have from purchasing this manual is my personal toll-free telephone number (888-561-2498). Feel free to call to ask questions about OSHA safety matters. It is like having a consultant on staff without the cost.

I am also associated with Occupational Safety Health Inspections, Inc. (OSHI), which offers complete and affordable OSHA and EPA on-site compliance services. In addition, we offer computer-based Internet training. Our goal is to provide employers and employees with programs and training needed to prevent workplace injuries and illnesses. This helps businesses avoid costly safety citations and saves them money by reducing workers' compensation claims and premiums.

I hope you will take the opportunity to review some of my other titles published by Summers Press. These include Automotive Workplace Guide to EPA and OSHA, California OSHA Compliance Guide, California OSHA Guide for the Construction Industry, EPA Compliance Guide for Hazardous Waste, OSHA Guide for the Construction Industry, OSHA Training Guide, California OSHA Training Guide, and my newest book, California OSHA Training Guide, Spanish Handouts and Tests. To review any or all of these titles for 30 days at no cost, call 800-743-6491.

Please let us know how we can be of service to you and your business. Call us toll-free at 888-561-2498 or visit our Internet site at http://www.oshi-inc.com.

Sincerely,

H. Ray Kirk, Ph.D.


Top OSHA Violations

The following are the most often violated OSHA standards for general industry during the period October 2000 through September 2001. Penalties shown reflect current rather than initial amounts. These standards are discussed in the Digest (Chapter 6).

STANDARD

VIOLATED

(CITATION)	$ PENALTY	DESCRIPTION	# CITED

1910.1200	$1,237,987.55	Hazard Communication 	7,412

1910.134	$1,133,132.31	Respiratory Protection	4,130

1910.147	$5,559,164.06	Control of Hazardous Energy,	4,038

Lock-Out/Tag-Out

1910.305	$1,078,472.14	Electrical, Wiring Methods,	3,222

Components, and Equipment

1910.212	$4,208,272.25	Machines, General Requirements	2,875

1910.178	$2,000,919.30	Powered Industrial Trucks	2,457

1910.303	$1,158,420.26	Electrical Systems Design,	2,287

General Requirements

1910.219	$1,473,659.56	Mechanical Power-Transmission	2,285

Apparatus

1910.1030	$863,547.12	Bloodborne Pathogens	2,009

1910.132	$1,716,068.46	Personal Protective Equipment,	1,992

General Requirements

1904.2	$2,063,842.08	Log and Summary of Occupational	1,702

Injury/Illnesses

1910.217	$1,066,971.05	Mechanical Power Presses	1,645

1910.157	$361,878.49	Portable Fire Extinguishers	1,495

1910.23	$1,492,474.05	Guarding Floor and Wall	1,481

Openings and Holes

1910.215	$463,712.75	Abrasive Wheel Machinery	1,344

For fiscal year 2001 (the most recent data available).


Table of Contents by Chapter

(A detailed Table of Contents for each chapter is located

at the beginning of that chapter.)

1	Overview of OSHA

Table of Contents

Introduction

Agency Basics

Employer Rights and Responsibilities

Employee Rights and Responsibilities

OSHA Inspections

Contesting Citations

Defenses to Citations

Compliance Assistance

2	Hazard Communication (Employee Right-to-Know)

Table of Contents

Introduction

Coverage of the OSHA Standard

Definition of Hazardous Chemicals

Container Labeling Requirements

Inventory of Hazardous Chemicals

Overview of MSDSs

Obtaining and Updating MSDSs

Employee Access to MSDSs

Excluded Products

Sample MSDSs

How to Read and Understand an MSDS

Employer's Form to Request an MSDS

Checklist of Required Information on an MSDS

3	Sample Safety Plans

Table of Contents

Introduction

Sample Emergency Action Plan

Sample Fire Safety Plan

Sample General Safety Plan

Sample Hazard Assessment Plan

Sample Hazard Communication Plan

4	Reporting, Recordkeeping, and Posting

Table of Contents

Introduction

Accident Reporting Requirements

Overview of Recordkeeping Requirements

Location and Retention of Records

Access to Records

Major Revisions in OSHA's New Recordkeeping Rule

Flow Charts of Recordable Cases

Determining Recordable Cases in the New Federal 300 and 301 Logs

Element 1: Work-Relatedness

Element 2: New Case

Element 3: Satisfying Recording Criteria

Entering Recordable Cases in the 300 Log

Completing and Posting Form 300A

Completing the 301 Log

New Form 300

New Form 300A

New Form 301

Partially Exempt Businesses

Posting Requirements

For Additional Information

5	Safety Inspection Checklists

Table of Contents

Introduction

Checklist Cover Sheet

Checklists

6	Digest of OSHA Safety Standards for General Industry

Table of Contents

Introduction

Digest

7	OSHA Training Requirements

Table of Contents

Introduction

Building a Training Program

OSHA Training: In General

Specific Training Topics

8	State OSHA Plans

Table of Contents

Introduction

States with OSHA-Approved Plans

State and Federal Standards

State Administration and Enforcement

State Recordkeeping/Reporting Requirements

Major State Standards

9	Directories

Table of Contents

Introduction

Abbreviations

States with Approved Plans

OSHA Regional and Area Offices

OSHA/State Consultation Project Directory

OSHA Internet Site


Table of Contents

Overview of OSHA

Introduction

Agency Basics

OSHA Defined

OSHA Creation

State Roles in OSHA

OSHA Coverage

Employer Rights and Responsibilities

Basic Employer Responsibilities

Basic Employer Rights

Protecting Trade Secrets

Employer Relief from a Specific Regulation

Obtaining a Variance

Employee Rights and Responsibilities

Basic Employee Rights

Basic Employee Responsibilities

OSHA Inspections

Common Triggers for an Inspection

Advance Notice of an OSHA Inspection

Scope of an Inspection

Process of a Typical Inspection

Verifying the Inspector's Credentials

Right to Demand a Search Warrant

Potential Drawbacks in Demanding a Warrant

Permissible Scope of a Warrant

Opening Conference Procedure

Inspection Procedure

Closing Conference Procedure

Tips for Surviving an Inspection

Contesting Citations

Right to Contest a Citation

Procedure to Contest a Citation

Time Period for Filing Citations

Role of Administrative Law Judges (ALJs)

Standard of Proof

Elements of Proof

Defeating a Citation

Penalties for OSHA Violations

Role of Lawyers in Contesting a Citation

Defenses to Citations

Basic Defenses to an OSHA Citation

Establishing Unpreventable Employee Misconduct

Impossibility of Compliance

Greater Hazard in Compliance

Vagueness of OSHA Standard

Reliance on OSHA Advice

Compliance Assistance

Professional Assistance

Getting Free Professional Assistance

OSHA Cooperative Programs

Use of Self-Audits


Introduction

Overview of OSHA

This chapter seeks to provide employers with a basic overview of how the Occupational Safety and Health Administration (OSHA) works. By reading this entire chapter, employers should be able to gain a clearer focus on the more detailed information in the later chapters. The chapter provides the basic framework on which OSHA's many specific standards are built.

Among the many important topics addressed by this chapter are the following:

•	OSHA's scope and authority

•	the role of states in occupational safety

•	employer rights and responsibilities

•	employee rights and responsibilities

•	the process for OSHA inspections

•	the procedure for contesting citations

•	the best evidence to defeat citations

•	different defenses to citations

•	ways to obtain compliance assistance


OSHA Defined

What is OSHA?

"OSHA" stands for Occupational Safety and Health Administration, an agency of the federal government. OSHA formally came into being in April, 1971, after passage of the Occupational Safety and Health Act. It is part of the U.S. Department of Labor.

OSHA's budget for fiscal year 2002 is $443 million. The agency has a staff of 2,316, including 1,123 inspectors (compliance officers). More than 20 states run their own OSHA-approved state programs. These have over 3,105 state employees, including 1,378 inspectors.


OSHA Creation

Why was OSHA created?

At the time that OSHA was created, employee safety was governed by a patchwork of state laws. Many of these state programs were ineffective, so that the number of occupational injuries and illnesses was alarmingly high. Since OSHA's creation, the occupational injury and illness rate has been cut in half.


State Roles in OSHA

What role can states play in occupational safety?

OSHA's rules generally preempt (supersede or replace) state safety laws. However, the Occupational Safety and Health Act allows states to administer their own safety and health plans by obtaining approval from federal OSHA. Over 20 states have done so (see States with OSHA-Approved Plans). To obtain federal OSHA's approval, a state must adopt safety regulations that are comparable to federal OSHA's. The standards need not be identical, as long as they are at least as effective. See State Recordkeeping/Reporting Requirements and Major State Standards for a brief sketch of unique state requirements.

Once federal OSHA approves a state plan, the state occupational safety and health agency has primary authority for enforcing occupational safety and health laws in that state. The state agency investigates workplace complaints and conducts inspections in place of federal OSHA.


OSHA Coverage

Who does OSHA cover?

Nearly every American employee is covered by OSHA (or an OSHA-approved state agency). The only significant exceptions are the following:

•	the self-employed;

•	coal miners;

•	atomic energy workers; and

•	public employees in state and local governments.


Basic Employer Responsibilities

What are an employer's basic responsibilities under OSHA?

Under the Occupational Safety and Health Act and its implementing regulations, an employer must comply with all of the following requirements:

•	General Duty Clause: Provide a workplace that is free from recognized hazards that could cause injury or death (see General Duty Clause).

•	Specific Standards: Ensure that employees comply with OSHA's specific standards and rules (see Digest of OSHA Safety Standards for General Industry).

•	Training: Make sure that employees receive all necessary training (see OSHA Training Requirements.)

•	Medical Examinations: Ensure that medical examinations are made available to employees as required (e.g., to employees who wear respirators or who suffer excessive lead exposure).

•	Hazard Assessment: Assess the workplace for hazardous conditions:

-	to determine if any administrative and engineering controls can control the hazard; and

-	to select appropriate personal protective equipment (PPE) for employees if other controls cannot eliminate the hazard.

Note: A Hazard Assessment Plan is included in Sample Safety Plans.

•	Tool and PPE Maintenance: Ensure that tools and personal protective equipment are properly maintained.

•	Accident Reporting: Report any work-related accident resulting in a fatality or the hospitalization of three or more employees (see Accident Reporting Requirements).

•	Recordkeeping: Comply with recordkeeping rules, including privacy requirements (see Major Revisions in OSHA's New Recordkeeping Ruleand Entering Recordable Cases in the 300 Log).

•	Record Access: Provide employees with access to work-related injury, medical, and exposure records (see Access to Records).

•	OSHA Survey: Respond if requested by the Bureau of Labor Statistics (see OSHA Survey).

•	Posting Requirements: Make sure to post:

-	the required OSHA poster at a prominent location in the workplace); and

-	OSHA citations and abatement verification notices (see Posting Requirements).

•	Hazard Abatement: Abate cited violations within the required period (see Abatement Certification, Generally).

•	Non-Discrimination: Do not discriminate against employees who exercise their rights under the Occupational Safety and Health Act.

29 U.S.C. §§ 654; 660

29 CFR 1910.132


Basic Employer Rights

What are an employer's basic rights under OSHA?

An employer generally is entitled to do all of the following under OSHA:

•	Comment on OSHA Proposals: Submit comments on the adoption or modification of OSHA rules.

•	Request Information on Toxic Substances: File a written request for information on potentially toxic substances in the employer's workplace with the National Institute of Occupational Safety and Health.

•	Use Consultation Services: Obtain free advice from consultation services that are independent of OSHA's enforcement arm (see Getting Free Professional Assistance).

•	Receive Proof of Compliance Officer's Credentials: Request and receive proper identification from an OSHA compliance officer (see Verifying the Inspector's Credentials).

•	Warrant Requirement: Demand that the OSHA compliance officer obtain a warrant to inspect the premises (although this may not be a good idea; see Right to Demand a Search Warrant).

•	Participate in the Inspection Process: Be informed and involved in all stages of any OSHA inspection (see Process of a Typical Inspection through the remainder of OSHA Inspections).

•	Protect Trade Secrets: Be assured that trade secrets are kept confidential (see Protecting Trade Secrets).

•	Request Variances: Apply for a temporary or permanent variance from an OSHA standard (see Employer Relief from a Specific Regulation).

•	Contest Citations: Require OSHA to prove any violations to an administrative law judge (see Standard of Proof).

29 U.S.C. § 670

29 CFR 1903.7


Protecting Trade Secrets

How does an employer protect trade secrets?

The Occupational Safety and Health Act requires compliance officers to keep trade secrets observed by them confidential. Federal employees who release confidential information without authorization are subject to severe criminal penalties.

An important consideration in determining whether something qualifies as a trade secret is the effort to guard its secrecy. Employers should take the following steps to protect their trade secrets from being disclosed as the result of any OSHA inspection:

•	Advance Preparation: Identify all trade secrets that need protection in advance of any actual OSHA inspection. If the employer does not raise the issue of trade secrets before a compliance officer inspects a particular area, the employer will be deemed to have waived its rights to assert trade secret protection.

•	Opening Conference: Attempt to convince the inspector not to examine any processes or activities that involve trade secrets. If that is unsuccessful, remind the compliance officer of his or her duty not to disclose trade secrets, as well as of the severe penalties for unlawful disclosure.

•	Special Labeling Requirements: Ensure that the compliance officer places the following labels on any photographs and samples taken from an area containing trade secrets:

"ADMINISTRATIVELY CONTROLLED INFORMATION"

"RESTRICTED TRADE INFORMATION"

•	Legal Assistance: Contact an attorney to discuss any problems or concerns involving trade secrets during the inspection process.

Trade secrets also may become an issue under the Hazard Communication Standard (see Hazard Communication (Employee Right-to-Know)). A manufacturer, importer, or employer may delete the specific chemical identity (including the chemical name and other identifying information for a hazardous chemical) of a trade secret from the MSDS under limited circumstances. In order for a manufacturer, importer, or employer to do so, all of the following conditions must be met:

•	the MSDS indicates that the specific chemical identity is being withheld as a trade secret;

•	the material safety data sheet (MSDS) discloses information concerning the properties and effects of the hazardous chemical; and

•	the specific chemical identity of the trade secret is revealed to health professionals and employees in medical emergencies.

29 CFR 1903.9; 1910.1200(i)


Employer Relief from a Specific Regulation

Can an employer seek relief from a specific regulation?

Yes, by obtaining a "variance." This is an order from OSHA that allows an employer to avoid a citation even though it does not comply with the exact terms of a particular safety regulation. Variances may be temporary or permanent. Temporary and permanent variances serve different purposes and involve different criteria.

Temporary variances may be sought if an employer's short-term problems prevent compliance with a particular safety regulation. For example, an employer might seek a temporary variance if it could not obtain necessary equipment or technical assistance. A temporary variance may be granted for a maximum of one year (with two additional 180-day extensions).

An employer should seek a permanent variance if it wants to permanently deviate from the exact terms of a specific OSHA regulation. To obtain such a variance, the employer must show that its alternative practices would be "as safe and healthful" as the particular regulation.


Obtaining a Variance

How does an employer obtain a variance?

The employer must file a formal application with OSHA that contains detailed information about the employer and the justification for the variance. The employer has the right to request and receive a hearing. In actual practice, most variance applications are handled less formally through OSHA's Office of Variance Determination.


Basic Employee Rights

What are an employee's basic rights under OSHA?

Employees have all of the following basic rights under OSHA:

•	Employer-Provided Information: Request and receive information from their employers on:

-	OSHA's rules and requirements;

-	mandatory measuring or monitoring of toxic substances; and

-	emergency procedures.

•	Safety Complaints: Make a complaint in confidence to OSHA concerning workplace safety conditions and receive a follow-up inspection or investigation (see Employee Complaints).

•	Training: Receive training as required by OSHA standards (see OSHA Training Requirements).

•	Participation during OSHA Inspections: Participate in the "walk-around" and learn the results of any inspection (see Inspection Procedure).

•	Participation in OSHA Consultative Services: Participate in the consultation and learn the results of the evaluation (see Consultative Services).

•	Refusal of Dangerous Work: Refuse to perform assigned work if:

-	the employee reasonably believes that a hazardous condition in the workplace poses a real threat of death or serious injury;

-	the employee requests the employer to correct the condition and the employer fails to comply; and

-	no less drastic alternative is available.

•	Examination of OSHA Records: Examine the employer's 300 Log as well as any 301 Logs that involve the particular employee (see Access to Records).

•	Hazardous Chemical Information: Obtain MSDSs and other basic information on hazardous chemicals in the workplace (see Hazard Communication (Employee Right-to-Know)).

•	Accessing Medical Records: View work-related medical and exposure records (see Medical Records, Access and Retention).

•	Contesting the Abatement Period: File a notice that the time for abating a hazard is unreasonable (must be filed within 15 days after issuance of any citation).

•	Participation in Enforcement Proceedings: Intervene in enforcement proceedings against the employer by filing a written notice at least 10 days before the hearing.

•	Protection from Discrimination: Exercise all OSHA rights without suffering discharge or discrimination, including:

-	filing a complaint;

-	contesting an abatement period; and

-	testifying or participating in an OSHA proceeding.

29 CFR 1903.17; 1908.6; 1910.1200; 1913.10; 1977.9; 1977.12


Basic Employee Responsibilities

What are an employee's basic responsibilities under OSHA?

Employees who disobey safety regulations are not subject to fines and penalties, in sharp contrast to the treatment of employers. However, the Occupational Safety and Health Act does recognize an employee's duty:

•	to obey OSHA safety regulations;

•	to follow the employer's health and safety rules; and

•	to wear prescribed personal protective equipment while working.

These employee duties enable an employer to discipline workers who break safety rules. In addition, these duties form the basis for the unpreventable employee misconduct defense (see Establishing Unpreventable Employee Misconduct).

29 U.S.C. § 654


Common Triggers for an Inspection

What are the most common triggers for an OSHA inspection?

The following are the most common triggers for an OSHA inspection, in order of priority:

•	Imminent Dangers: Notification that a workplace condition or practice threatens employees with death or serious physical harm.

•	Serious Accidents: Reporting of a work-related fatality or accident that results in the hospitalization of three or more employees (see Accident Reporting Requirements).

•	Employee Complaints: Written complaints that meet certain conditions. (Other complaints will first lead to a less formal investigation, not an actual on-site inspection.) (See Employee Complaints.)

•	Involvement in a Site-Specific Targeting (SST) Plan or National Emphasis Program: Selection of the employer through an inspection program that uses neutral or objective criteria (see Site-Specific Targeting (SST) Plan).


Advance Notice of an OSHA Inspection

Can I get advance notice of an OSHA inspection?

No. Advance notice of inspections generally may not be given and is punishable by fines of up to $5,000. However, advance notice is not prohibited:

•	in cases of apparent imminent danger, to enable the employer to abate the danger as quickly as possible;

•	where the inspection can most effectively be conducted after regular business hours or where special preparations are necessary;

•	where necessary to assure the presence of:

-	representatives of the employer and employees; or

-	the appropriate personnel to aid in the inspection; and

•	in other circumstances where the OSHA Area Director determines that the giving of advance notice would increase the likelihood of an effective and thorough inspection.

Except in cases of apparent imminent danger, advance notice may be authorized only by the Area Director. In cases of imminent danger, advance notice may be given by the OSHA inspector when the Area Director is not immediately available.

29 CFR 1903.6


Scope of an Inspection

What is the scope of an inspection?

An inspection may be either comprehensive or partial. Comprehensive inspections involve a complete "wall-to-wall" inspection of the workplace. Typically, a comprehensive inspection occurs as part of an OSHA program that uses objective or neutral criteria to select employers for evaluation. Examples of such programs are OSHA's national emphasis programs, as well as its Site-Specific Targeting (SST) plan.

Partial inspections are limited to certain workplace conditions or practices and typically are "unprogrammed." An unprogrammed inspection generally arises from an employee complaint or a reported situation involving an imminent danger to employees. A partial inspection may be expanded to include other hazards based on the compliance officer's observations in the workplace. In OSHA's terminology, an expanded inspection resulting from a partial inspection is an "unprogrammed related inspection."


Process of a Typical Inspection

How does the typical inspection proceed?

The typical inspection consists of the following four stages:

•	Stage 1: Presentation of inspector's credentials

•	Stage 2: Opening conference

•	Stage 3: Facility inspection ("walk-around")

•	Stage 4: Closing conference


Verifying the Inspector's Credentials

Should an employer verify the inspector's credentials?

Yes, the Occupational Safety and Health Act specifically requires the OSHA inspector (compliance officer) to identify himself or herself and to display official U.S. Department of Labor credentials.


Right to Demand a Search Warrant

Can an employer demand a search warrant?

Yes, the courts have ruled that the U.S. Constitution generally requires an inspector (compliance officer) to obtain a search warrant to conduct an inspection, unless the employer voluntarily agrees to allow the inspector in. This general warrant requirement is subject to several important exceptions. A search warrant is not required for an inspector to enter the part of a business that is open to the public. In addition, several courts have ruled that employers have no expectation of privacy in areas of a construction site that are in "plain view." For this reason, OSHA may be able to cite an employer for plainly visible violations on a construction site without first obtaining a search warrant.

Marshall v. Barlow's, 436 U.S. 307 (1978)

Tri-State Steel Constr., Inc. v. OSHRC, 26 F.3d 173 (D.C. Cir. 1995), cert. denied, 514 U.S. 1015 (1995)


Potential Drawbacks in Demanding a Warrant

Should an employer demand a warrant?

The standard for obtaining an administrative warrant to conduct an OSHA inspection is much lower than the probable cause standard that applies to warrants in criminal cases. OSHA must merely show that the inspection arises from a complaint or is part of a reasonable enforcement plan. This means that the employer may be able to "buy some time" by requesting a warrant, but cannot prevent an inspection altogether.

The main drawback to demanding a warrant is that the compliance officer is likely to resent the extra effort. During the inspection, the officer may then exercise his or her discretion in a way that expresses that resentment. Unless there is a specific reason to force the inspector to obtain the warrant, an employer generally is better off allowing an inspection without a warrant.

By allowing entry of the inspector without a warrant, the employer does not cause OSHA to waive its right to cite or fine the employer.


Permissible Scope of a Warrant

How broad an inspection does a warrant authorize?

This may vary depending on the reason for the inspection and whether the inspection is "programmed" or "unprogrammed." In the case of a programmed inspection, a business is selected based on an OSHA administrative plan (e.g., the Site-Specific Targeting plan). An unprogrammed inspection results from a complaint or report regarding a specific health or safety problem, rather than from the employer's selection as part of an administrative program.

A warrant for a programmed inspection clearly authorizes the compliance officer to conduct a comprehensive, "wall-to-wall" search. However, several federal courts have held that a different rule applies in cases of unprogrammed inspections that arise from employee complaints. According to these judicial decisions, the compliance officer generally must limit his or her inspection to the specific condition that led to the complaint. Other courts have taken a different view and concluded that a warrant for an unprogrammed inspection will support a comprehensive search.

In any event, the federal courts agree that special circumstances will entitle a compliance officer to broaden the scope of an unprogrammed inspection. For example, if the officer unexpectedly happens to observe an additional hazard during a limited inspection, he or she may further investigate the matter.

Trinity Industries, Inc. v. OSHRC, 16 F.3d 1455 (6th Cir. 1994)

Donovan v. Burlington Northern, Inc., 694 F.2d 1213 (9th Cir. 1982), cert. denied, 463 U.S. 1207 (1983)


Opening Conference Procedure

What happens during the opening conference?

During the opening conference, the compliance officer covers the basics of the inspection with the employer's representative:

•	Reason for Selection: Explains why OSHA selected the establishment for inspection (e.g., employee complaint, national emphasis program). The employer has the right to see a copy of any complaint, but not the name of the complaining employee.)

•	Overview of the Inspection: Explains:

-	the scope of the inspection;

-	the procedures for inspection;

-	the participation rights of employees;

-	the procedures for employee interviews; and

-	the closing conference.

•	Possible Exemption: Determines whether an OSHA-funded consultation program is in progress so that the employer is actually exempt from inspection (see Consultative Services).

•	Examination of Records: Reviews the OSHA 300 Log to identify trends (may also review the OSHA 301 Logs and other relevant records).

•	Opportunity for Employer Participation: Asks the employer to select an employer representative to accompany him or her during the inspection.

•	Opportunity for Employee Participation: Asks for an employee representative to participate in the inspection, as follows:

-	If the employees have a union, it will select the representative.

-	If there is a safety committee (but no union), the committee may designate the representative.

-	If there is neither a union nor a safety committee, the employees or the compliance officer selects the representative.

-	Under no circumstances may the employer select the employee representative.

-	The selection of an employee representative is preferred by OSHA, but not required. In the absence of such a representative, the compliance officer must consult with a reasonable number of employees about safety and health matters.


Inspection Procedure

What happens during the actual inspection?

The heart of the actual inspection involves the "walk-around." The compliance officer and accompanying representatives proceed through the establishment to inspect work areas for potentially hazardous working conditions.

If an employer is targeted as part of a programmed inspection, OSHA generally will conduct a comprehensive (i.e., "wall-to-wall") search. If the inspection results from an employee complaint, the compliance officer generally will focus on the problems and practices related to the complaint. However, the officer may attempt to expand the inspection if a review of the employer's records or premises reveals additional problems (see Permissible Scope of a Warrant).

During the actual inspection, the compliance officer may engage in any or all of the following activities:

•	check the employer's posting and recordkeeping practices, including whether the employer has posted a copy of the Annual Summary (OSHA Form 300A) and prominently displayed the required OSHA poster

•	examine records, where required, of employee exposure to toxic substances and harmful physical agents

•	videotape or take pictures of workplace conditions and safety violations

•	sample environmental conditions (e.g., noise levels, air contaminants)

•	discuss possible corrective actions for any hazardous conditions that are detected

Note: The employer's willingness to immediately correct any problems may help to show its good faith and to reduce its penalties. However, even though violations are immediately corrected, they may still serve as the basis for a citation.

•	consult with employees during the inspection walk-around

The employer's representative has the right to insist on being present at any employee consultations (unless a warrant specifically authorizes private employee conferences). However, such insistence is unlikely to accomplish much, other than irritating the compliance officer. The officer may simply get the employee's name and phone number and arrange for an interview outside of the workplace. In addition, the officer can obtain a warrant or subpoena to compel private testimony. In short, the employer should object to a private interview only if there is a very good reason to do so.


Closing Conference Procedure

What happens during the closing conference?

The compliance officer holds the closing conference with the employer and employee representatives, either jointly or separately, as circumstances dictate. Compliance officers generally encourage joint closing conferences. However, the employer may choose to have a separate closing conference. During the closing conference, the compliance officer:

•	describes the apparent violations found during the inspection;

•	advises the employer of:

-	its obligations regarding any citations;

-	the procedures for contesting any citations;

-	the informal settlement conference procedures that are available; and

-	the duty not to discriminate against employees who exercise their rights under the Occupational Safety and Health Act; and

•	advises employees of their right to contest the abatement period and to participate in administrative proceedings.


Tips for Surviving an Inspection

How does an employer survive an inspection?

The following list of inspection "Do's" and "Don'ts" provides some practical pointers on surviving an OSHA inspection.

Do's

•	Attorney Consultation: Consult with an attorney if you have any special questions or concerns (most likely if the OSHA investigation occurs because of a fatality or serious accident).

•	Staying with the Officer: Make sure that an employer's representative remains with the compliance officer throughout the inspection.

•	Taking Notes: Take detailed notes during the inspection, especially regarding what the compliance officer appears to write down.

•	Double Checks for Samples, Tests, and Photos: Ensure that a representative of the employer takes a sample, test, or photo to match each one taken by the OSHA inspector. (This information may be both helpful and harmful, since it will provide a double check on OSHA, but may create evidence that can be used against the employer.)

•	Safety Gear: Ensure that the inspector is given any necessary personal protective equipment and is advised of applicable safety rules so that the employer's adherence to its own safety rules will not be questioned.

•	Scheduling Employee Interviews: Although compliance officers generally have the right to consult with employees during an inspection, employers should try to schedule any employee interviews to minimize disruptions to business operations.

•	Allowing Private Interviews: Permit private interviews with employees unless there is a very good reason to object (see Inspection Procedure). However, keep the compliance officer in sight while he or she is talking to the employee.

•	Objecting to Short Abatement Periods: Object to any unreasonably short periods for abating alleged violations. However, be careful not to admit to any violation or to waive the right to contest a citation in objecting to an unreasonably short abatement period.

Don'ts

•	Volunteering Information: Be cooperative, but don't volunteer information during the walk-around, as this may enable the compliance officer to ask more questions, discover more violations, and issue more citations.

•	Performing Needless Demonstrations: Don't perform unnecessary demonstrations of operations or processes during the inspection, as this may enable the compliance officer to ask more questions, discover more violations, and issue more citations.

•	Admitting to Violations: Don't admit to violations, as the admission may be used against an employer that later objects to a citation or tries to negotiate a reduced penalty.

•	Intimidating Employees: Don't engage in any conduct that may be perceived as intimidation of employees, as this conduct is unlawful and may even lead to a "retaliatory discharge" claim if an employee is later terminated for any reason.


Right to Contest a Citation

What right does an employer have to contest a citation?

The thought of an OSHA citation and fine is enough to cause heartburn in most employers. However, the issuance of a citation does not automatically mean that the employer is guilty. In fact, OSHA has the burden to prove each essential element of the violation (see Standard of Proof).

The employer may contest any or all of the following:

•	the citation

•	the amount of the proposed penalty

•	the abatement period

29 CFR 1903.17


Procedure to Contest a Citation

How does an employer contest a citation?

To fight a citation, the employer must file a written contest within 15 working days of receipt of notice of the proposed penalty. The contest should state whether the employer is challenging the violation, the proposed penalty, or both matters. The contest must be postmarked (or delivered) within 15 working days of receipt of the notice of proposed penalty. Generally, an employer that fails to file a contest within the 15-day deadline cannot fight the citation.

The contest is filed with the OSHA Area Director. By filing a contest, the employer also delays the running of the abatement period. (See Abatement Certification, Generally and Posting Requirements regarding citations.)

Employers may also request an informal settlement conference with the Area Director within the 15-day deadline. The conference may lead to a reduced fine and a settlement between the parties. However, requesting an informal settlement conference is not a substitute for filing an actual written notice of contest within the 15-day deadline.

29 CFR 1903.17


Time Period for Filing Citations

Does OSHA have a time limit to file a citation?

Yes. OSHA is required to cite the employer within six months of the occurrence of the violation (generally the date of the inspection or investigation). A citation will be dismissed if the employer objects to it being filed beyond the six-month deadline.

Southern Nuclear Operating Co., Inc., 1999 OSAHRC LEXIS 68; 18 OSHC (BNA) 1871 (1999)


Role of Administrative Law Judges (ALJs)

Who decides disputed cases?

Disputed cases are heard by administrative law judges (ALJs). They work for the Occupational Safety and Health Review Commission, which is independent of OSHA itself. Decisions of the ALJs may be appealed to the Review Commission. It has broad authority to overrule a judge's decision or to reduce any penalty.

The decisions of the Review Commission may, in turn, be appealed to the federal courts. The courts extend the Review Commission a considerable degree of deference. Generally, they will overturn a Review Commission decision only if it involves a significant misapplication of the law or gross disregard of the evidence.

In states with OSHA-approved plans, disputed cases are heard by state review commissions, with further appeals to the state courts.


Standard of Proof

What is the standard of proof?

OSHA generally has the burden of proof to establish a violation. This means that the agency must convince the judge that the greater weight of the evidence ("preponderance of the evidence") establishes all of the elements of the particular violation. If the evidence tilts in OSHA's favor, even by a tiny bit, the agency wins its case.

Affirmative defenses are treated differently, however. With an affirmative defense, an employer does not deny the existence of a violation, but seeks to establish special facts to excuse or justify it. The employer generally has the burden to prove each element of any affirmative defense. The most common affirmative defense is that of unpreventable employee misconduct (see Establishing Unpreventable Employee Misconduct).

In determining whether OSHA has proved its case, the administrative judge weighs the credibility of the witnesses. The fact that the employer calls several witnesses to rebut the testimony of a single compliance officer does not necessarily mean that the employer will win its case. As the fact-finder, the ALJ may choose to believe the testimony of the compliance officer or other witnesses over that of the employer's witnesses. In addition, human memory and perception can easily be mistaken, despite the best of intentions. For this reason, documentary and objective evidence often carries the most weight with judges (see Defeating a Citation).

If OSHA brings criminal charges, vastly different standards and procedures apply. The agency must prove that the employer is guilty beyond a reasonable doubt to a jury (see Fines and Penalties, Criminal Offenses).

Bredshall Plastering, Inc., 2001 OSAHRC LEXIS 27; 19 OSHC (BNA) 1449 (2001)

United States v. Ladish Malting Co., 135 F.3d 484 (7th Cir. 1998)


Elements of Proof

What are the elements of proof?

To establish the violation of any OSHA standard or the general duty clause, the agency must prove:

•	that the employer violated an applicable standard or the general duty clause;

•	that employees had "access" (were exposed) to the offending condition; and

•	that the employer had actual or constructive knowledge of the offending condition.

Employee access to and employer knowledge of the offending condition are both relatively easy to prove. If it is "reasonably predictable" that an employee could be exposed to a condition (even accidentally), access is established. To demonstrate actual or constructive knowledge of a condition, OSHA must merely show what a reasonably diligent employer ought to have known. If a manager or supervisor of the employer should have known of a particular condition, the employer will be deemed to have knowledge of its existence.

Proof of additional facts by OSHA is required to support some citations. For example, a "willful" violation requires proof that the employer acted with reckless disregard of agency requirements and also carries ten times the potential fine of an ordinary violation (see Fines and Penalties, Classification and Assessment). For this reason, an employer would benefit greatly from contesting and defeating a charge of willfulness, even if it could not disprove the non-willful occurrence of the violation.

Bredshall Plastering, Inc., 2001 OSAHRC LEXIS 27; 19 OSHC (BNA) 1449 (2001)


Defeating a Citation

What is the best kind of evidence to defeat a citation?

To answer this question, imagine the following hypothetical. A compliance officer cites an employer for failing to provide hearing protective devices. However, there was a problem with the inspector's measuring instrument (dosimeter), so that the citation is unfounded. The actual noise levels were within permissible limits. What is the best way to convince the judge that the inspector was mistaken?

Testimony from witnesses that "the noise really wasn't that loud" is unlikely to do the job. But if the employer has taken its own objective measurements that contradict the inspector's, the employer stands a decent chance of winning the case. That is why the employer needs to take a sample, test, or photo to match each one taken by the OSHA inspector (see Tips for Surviving an Inspection).

To add a slight wrinkle to the above hypothetical, suppose the employer is cited because the inspector does not understand its administrative controls. The employer regularly rotates the areas where employees are assigned to work so that no one actually suffers excessive noise exposure. In this example, the employer cannot provide an objective test to prove its innocence. However, if the employer has documentary proof, that is the next best thing. The judge is more likely to believe in the employer's work practice controls if they are supported by a written program or policy as well as verbal testimony.

In short, the best way to fight a citation is through documentary and objective evidence. It is more likely to persuade a judge than somebody's vague recollection of what took place months before.


Penalties for OSHA Violation

What are the penalties for OSHA violations?

Violations of OSHA standards may result in fines of up to $7,000 for each serious and other-than-serious violation (see Fines and Penalties, Classification and Assessment). In addition, willful and repeated violations are subject to fines of up to $70,000 per violation. Finally, employers may be fined up to $7,000 per day for each day that they fail to abate a hazard.

OSHA fines generally are subject to adjustment (reduction) based on an employer's size, good faith, and safety history (see Fines and Penalties, Adjustments). However, criminal fines are not subject to any adjustment. Employers may be prosecuted criminally if the willful violation of an OSHA standard causes the death of an employee (see Fines and Penalties, Criminal Offenses).

29 U.S.C. § 666


Role of Lawyers in Contesting a Citation

Should the employer get a lawyer to contest a citation?

In contesting a citation, the employer would often benefit from securing the services of an attorney who specializes in employment law. Testimony that is heard by ALJs must comply with special rules of evidence to be admissible. In addition, there are a number of technicalities, such as special pleading requirements, that can trap the inexperienced lay person.

Of course, attorneys are quite expensive. The services of an attorney may not be cost effective, especially for relatively minor citations that involve small potential fines. In addition, employers are often eligible for a number of adjustments for good faith, safety history, etc. that may reduce any penalty significantly.

On the other hand, an attorney may be able to significantly lower a fine simply by pointing out possible defenses and negotiating on the employer's behalf. The negotiation of a compromise is usually much less expensive than the participation of an attorney at the administrative trial.


Basic Defenses to an OSHA Citation

What are the basic defenses to an OSHA citation?

Most defenses to citations can be placed into one of three basic categories:

•	Inadequate Proof of Essential Elements:

-	no actual violation of an applicable standard or general duty clause

-	no employee "access" (exposure) to the offending condition

-	no actual or constructive knowledge by the employer of the offending condition

•	Affirmative Defenses:

-	unpreventable employee misconduct

-	impossibility or infeasibility of compliance

-	greater hazard in compliance than non-compliance

•	Problem with the Standard or Its Enforcement:

-	impermissibly vague standard

-	reasonable reliance on OSHA's guidance or advice


Establishing Unpreventable Employee Misconduct

What is required to establish unpreventable employee misconduct?

Research has shown that unsafe acts by employees are far more common than unsafe conditions. For this reason, the "unpreventable employee misconduct defense" (also known as the "isolated employee misconduct defense") has a natural appeal to employers. In many employers' eyes, they should not be liable for employees who foolishly endanger themselves through their own misconduct. However, as a general rule, OSHA regards employers as responsible for all of the actions of their employees. The unpreventable employee misconduct defense will succeed only if the employer can prove that it was completely committed to the safety of its non-complying employees.

To establish the unpreventable employee misconduct defense, the employer has the burden of proving that it:

•	adopted effective work rules to prevent the violation;

•	communicated these rules to employees (i.e., the non-complying employee was well-informed and well-trained regarding the rule);

•	acted diligently to discover instances of non-compliance; and

•	enforced the rules effectively to deter violations (i.e., repeated violations of the rule resulted in real disciplinary measures, not mere verbal reprimands).

As with any defense, an employer is more likely to succeed if it has documentation for support including records of training sessions and of disciplinary action (see Defeating a Citation). But to prevail, the employer must also show that it enforced the particular safety rule in reality as well as in writing.

Omaha Paper Stock Co., 2001 OSAHRC LEXIS 100; 19 OSHC (BNA) 1584 (2001)


Impossibility of Compliance

What if compliance would be impossible?

An employer may defeat a citation by proving that compliance with a standard was impossible. However, this affirmative defense is very difficult to establish. It requires the employer to prove:

•	that compliance with the standard's requirements was impossible or would have made performance of the work impossible; and

•	that there were no alternative means to protect employees.

In one case, the employer was cited for failing to use engineering and administrative controls to reduce employee noise exposure to acceptable levels. The employer had taken a number of steps to reduce noise, including spending over $90,000 on sound reduction equipment. Several technical representatives from the manufacturers of the noisy machinery testified that there was nothing more that the employer could do to reduce the noise. The Review Commission found that the employer's evidence did indeed establish the defense of impossibility or infeasibility of compliance.

Except in the most extreme circumstances, this affirmative defense is unlikely to be a winner. It may be easy to show that following an OSHA standard would be burdensome or difficult. However, it is a very heavy burden to persuade the Review Commission and the courts that compliance would truly be impossible.

International Paper Co., 1974 OSAHRC LEXIS 172; 2 OSHC (BNA) 3173 (1974)


Greater Hazard in Compliance

What if compliance would create a greater hazard?

An employer may also defeat a citation by proving that compliance with an OSHA standard was more dangerous than non-compliance. This affirmative defense requires proof of the following elements:

•	compliance with the standard would pose a greater hazard to employees than non-compliance;

•	no alternative means of employee protection exist; and

•	a variance is unavailable or inappropriate (see Employer Relief from a Specific Regulation).

As a general rule, the greater hazard defense is extremely difficult to prove. The Review Commission and the courts are very reluctant to conclude that ignoring agency rules is a better idea than following them. There are a few exceptions, however. In one case, the employees would have had a greater risk of falling from constructing a required guardrail than from simply performing the task for which the guardrail was supposed to provide protection. The court ruled that the employer had established the greater hazard defense.

H.S. Holtze Constr. Co. v. Marshall, 627 F.2d 149 (8th Cir. 1980)

E & R Erectors, Inc. v. Secretary of Labor, 107 F.3d 157 (3d Cir. 1997)


Vagueness of OSHA Standard

What if the OSHA standard is too vague?

A citation may be attacked if it is based on a standard that is too vague to give fair notice of the conduct that it prohibits or demands. In determining whether a standard is too vague, the courts will look to agency interpretations and industry customs to "flesh out" the meaning. With very few exceptions, employer attacks on standards for their vagueness have failed. The employer is most likely to succeed where the agency has provided an interpretation to clarify a broad standard, which it then refuses to follow (see Reliance on OSHA Advice).

In addition, employers should remember that they may be cited for violating the general duty clause even in the absence of a specific standard (see General Duty Clause). This clause requires employers to furnish a workplace free from recognized hazards that could cause death or serious injury to employees. Before an employer may be cited under the general duty clause, fair notice requires that a "reasonable man familiar with the conditions of the industry would have instituted the [required] protective measure . . . ."

S & H Riggers & Erectors, Inc. v. OSHRC, 659 F.2d 1273 (5th Cir. 1981)

Spancrete Northeast, Inc. v. OSHRC, 905 F.2d 589 (2d Cir. 1990)


Reliance on OSHA Advice

What if the employer relies on OSHA's advice?

In determining how to apply OSHA standards, employers often rely on additional information from OSHA. This may be found in interpretive letters or even in comments from OSHA personnel. For example, in one case, the employer relied on statements from a compliance officer who expressly approved of its method of machine guarding. The Review Commission ruled that OSHA was prevented ("estopped") from citing the employer, since it reasonably relied on the officer's advice.

The Commission is most receptive to a reasonable reliance defense involving the interpretation of a general standard subject to several possible readings. An employer that requests an interpretation from OSHA may object if the agency changes its mind and then cites the employer. Yet the agency has considerable latitude to revise interpretations to pursue evolving policy objectives. For this reason, the success of this defense can be unpredictable. It generally requires a strong showing to succeed, including proof that an agent of the government committed "affirmative misconduct" (e.g., made repeated assurances that the employer's practices were acceptable).

The mere fact that OSHA inspected an employer and did not complain about a particular condition does not prevent the agency from citing the employer for that condition during another inspection.

Fluor Daniel, 2001 OSAHRC LEXIS 86; 18 OSHC (BNA) 1529 (2001)

Hamilton Die Cast, Inc., 1984 OSAHRC LEXIS 106; 11 OSHC (BNA) 2169 (1984)


Professional Assistance

How can an employer know if it is in compliance?

Despite an employer's best efforts, it can be very difficult to achieve perfect compliance with OSHA's many regulations. That is why an employer can often benefit from the advice of a safety professional.


Getting Free Professional Assistance

Can an employer get free assistance?

Yes, an employer can get free help in each state through on-site consultative services (see Consultative Services). The services are independent of OSHA's enforcement arm and generally must be kept confidential from the enforcement authorities. However, an exception allows the consultant to notify OSHA if the employer fails to promptly correct any imminent dangers.

For contact information on each state's consultation services, see OSHA/State Consultation Project Directory.

29 U.S.C. § 670

29 CFR 1908.1


OSHA Cooperative Programs

Do any OSHA programs emphasize cooperation with employers?

Yes, the Voluntary Protection Program (VPP) and the Safety and Health Achievement and Recognition Program (SHARP) emphasize cooperation and teamwork between management and government to achieve compliance, rather than the more traditional threat of citations and fines.

The VPP is administered by OSHA itself. The SHARP is administered as part of each state's consultative services, which are independent of OSHA's enforcement arm (see Consultative Services).

Employers that have good safety records (below-average injury and illness rates) and meet stringent eligibility requirements are eligible for VPP participation. As a reward for their participation, VPP employers are removed from OSHA's programmed inspection list for a period of 12 months. For a detailed discussion on participation in the VPP, see Voluntary Protection Program (VPP).

Small employers (i.e., those with fewer than 250 employees at one site or 500 employees company-wide) in high-hazard industries may participate in SHARP. To be eligible, employers must also have good safety records. Participating employers receive an exemption from a programmed OSHA inspection for a period of up to 18 months. For more details on SHARP, see SHARP Participation.


Use of Self-Audits

Are self-audits a good idea?

Most employers perform self-audits to verify their compliance with OSHA's many safety regulations (see Self-Audits). Regular self-audits usually help employers to improve their safety practices. However, they also have a potential drawback. Many employers fear that written records of self-audits may be used by OSHA to help establish safety violations.

In response to these concerns, OSHA has adopted a policy that it will not "routinely request" records of self-audits when initiating an inspection. The policy applies to audits performed by the employer and by third parties hired by the employer. To be covered by the policy, an audit must be systematic, documented, and objective. However, it need not be comprehensive.

OSHA's self-audit policy is clearly a step in the right direction. However, a number of commentators have expressed concern that the policy still gives OSHA too much discretion to examine the self-audit records.


Table of Contents

Hazard Communication (Employee Right-to-Know)

Introduction

Coverage of the OSHA Standard

Definition of Hazardous Chemicals

Container Labeling Requirements

Inventory of Hazardous Chemicals

Overview of MSDSs

Obtaining and Updating MSDSs

Employee Access to MSDSs

Excluded Products

Sample MSDSs

How to Read and Understand an MSDS

Section I - Identity

Section II - Hazardous Ingredients/Identity Information

Section III - Physical/Chemical Characteristics

Section IV - Fire and Explosion Hazard Data

Section V - Reactivity Data

Section VI - Health Hazard Data

Section VII - Precautions for Safe Handling and Use

Section VIII - Control Measures

Employer's Form to Request an MSDS

Checklist of Required Information on an MSDS


Introduction

Hazard Communication (Employee Right-to-Know)

This chapter provides a basic overview of OSHA's Hazard Communication Standard (also known as the "Employee Right-to-Know Regulation"). The standard requires employers to inform their employees about the hazardous chemicals in their workplaces. This is no simple task. The number of chemicals covered is huge. Approximately 650,000 hazardous chemicals are used on the job, and hundreds of new chemicals are introduced every year.

The materials in this chapter place special emphasis on the requirements regarding Material Safety Data Sheets (MSDSs). MSDSs are the primary source for informing employees about any hazardous chemicals in their workplaces. In addition to providing MSDSs, affected employers must inform and train their employees through a written Hazard Communication Plan. A sample plan is located in Sample Safety Plans. Employee training requirements are discussed in Hazard Communication. The protection of trade secrets from disclosure is discussed in Protecting Trade Secrets.


Coverage of the OSHA Standard

The Hazard Communication Standard applies to all employees who may potentially be exposed to hazardous chemicals "known to be present in the workplace." This includes chemicals to which employees may be exposed during normal operations or in foreseeable emergencies (e.g., equipment failure, container rupture). However, there are several categories of chemicals that are excluded from coverage under the standard (see Excluded Products).

Employers are required to warn their employees of hazardous chemicals through:

•	container labels (see Container Labeling Requirements)

•	Material Safety Data Sheets or MSDSs (see Overview of MSDSs through the end of the chapter); and

•	hazard communication plans (see Sample Hazard Communication Plan).

In addition to informing their own employees of the hazards from workplace chemicals, employers also must advise outside contractors of the following:

•	chemical hazards that may be encountered on the employer's premises; and

•	protective measures:

-	labeling systems;

-	safe handling procedures; and

-	the location and availability of MSDSs.

In turn, each contractor that brings hazardous chemicals on-site must disclose appropriate information to employers, including MSDSs, labels, and necessary precautionary measures.

29 CFR 1910.1200


Definition of Hazardous Chemicals

Under the Hazard Communication Standard, OSHA automatically considers a chemical as hazardous if it is identified in any of the following publications:

•	National Toxicology Program (NTP), Annual Report on Carcinogens

•	Subpart Z, Toxic and Hazardous Substances, in OSHA's general industry standards

•	American Conference of Governmental Industrial Hygienists (ACGIH), Threshold Limit Values for Chemical Substances and Physical Agents

•	International Agency for Research on Cancer (IARC), Monographs

In addition, the standard covers any substance that poses a physical or health hazard, even if it is not on any of the preceding lists.


Container Labeling Requirements

Employers must make sure that each container of hazardous chemicals is labeled, tagged, or marked. The label must:

•	identify the hazardous chemical;

•	name the manufacturer; and

•	provide appropriate hazard warnings for employee protection.

29 CFR 1910.1200


Inventory of Hazardous Chemicals

Every employer must develop a list (inventory) that identifies all of the hazardous chemicals in the workplace. The name of the material must come from the appropriate Material Safety Data Sheets (see Overview of MSDSs). The inventory may be compiled for the workplace as a whole or for individual work areas.

In performing the inventory, the employer should take the widest possible view of what may qualify as a hazardous chemical. The employer must identify chemicals in containers, including pipes. In addition, the employer should remember that chemicals come in many forms, including liquids, solids, gases, fumes, and mists.

29 CFR 1910.1200


Overview of MSDSs

Every manufacturer and importer of hazardous chemicals must develop a Material Safety Data Sheet (MSDS) to be provided with each of their products. MSDSs are the main mechanism for informing employees about the dangers from chemicals in the workplace. Each MSDS provides detailed information on the hazards and properties of the particular chemical. Employers are entitled to rely on the information that is provided on the MSDSs to determine the properties of hazardous chemicals. Employers are not required to perform their own analysis or evaluation of the chemicals.

Under the Hazard Communication Standard, the main responsibilities of employers are:

•	to inventory their workplaces to ensure that employees have access to an MSDS for every hazardous chemical in the workplace (see Inventory of Hazardous Chemicals); and

•	to train employees on recognizing the dangers of hazardous chemicals and on using MSDSs (see Hazard Communication).

To ensure the widest distribution of the information, OSHA requires MSDSs to "flow downstream." This means that manufacturers must send a copy of an MSDS with each chemical product shipped to their distributors. Distributors, in turn, must make sure that an MSDS is sent to each purchaser of the product. On occasion, this downstream flow of information is inadvertently interrupted. For this reason, a purchaser from a distributor is also entitled to obtain a copy of an MSDS on request from the original manufacturer of the product.

29 CFR 1910.1200


Obtaining and Updating MSDSs

The first time that an employer orders a particular chemical, the manufacturer or distributor must include a copy of the MSDS. Except for the initial shipment, the chemical supplier generally is not required to include an MSDS with the shipment.

An employer that loses the MSDS that came with the initial shipment must obtain another copy. Many chemical suppliers voluntarily include an MSDS with every product shipment. In addition, suppliers must provide another copy of an MSDS on request. Finally, many databases containing MSDSs may be accessed on the Internet. In fact, there are a number of commercial services that provide electronic access to MSDSs (see Employee Access to MSDSs).

Updates

Manufacturers and importers must update an MSDS whenever:

•	the product's chemical composition changes; or

•	new information is obtained concerning its hazards.

An employer will automatically receive an updated MSDS only if it purchases the product after the MSDS has been changed. However, the employer must stay current on chemical hazards by requesting updated MSDSs from its suppliers regarding chemicals used by the employer.

29 CFR 1910.1200


Employee Access to MSDSs

Employers must provide their employees with ready access to any required MSDSs. In addition, employers cannot impose any barriers to that access. This means that employees should be able to obtain access without having to ask a supervisor for permission. It also means that MSDSs should not be kept under lock and key, but should be freely accessible.

Employers may choose to keep a file with paper copies of MSDSs or to provide employees with electronic access (e.g., from a computer). However, if an employer chooses to provide electronic access, it must ensure that all of the following conditions are met:

•	employees are trained on how to access MSDSs electronically;

•	employees are given reliable devices for obtaining access;

•	employees have a back-up system in case of a power outage, equipment failure, on-line access delay or similar problem; and

•	employees are allowed to obtain hard copies of the MSDSs if they want them.

29 CFR 1910.1200

See Sample MSDSs for a sample MSDS.


Excluded Products

MSDSs are not required for certain chemical products that are excluded from coverage under the Hazard Communication Standard. These products include the following:

•	ordinary consumer products if their use in the workplace is the same as that of a typical consumer (discussed further below)

•	products that meet the definition of an article (discussed further below)

•	cosmetics packaged for sale to consumers in retail stores or used by employees for personal consumption in the workplace (However, MSDSs are required for beauty salon employees who make occupational use of the products.)

•	tobacco and tobacco products

•	hazardous wastes regulated by the EPA

•	wood or wood products unless:

-	the wood may generate dust (be sawed or cut); or

-	the wood has been treated with a hazardous chemical.

•	biohazardous materials, such as microbes, anthrax, vaccines, and cell cultures

•	drugs intended for personal consumption by employees while in the workplace (e.g., first aid supplies)

•	drugs in solid final form (e.g., tablets or pills) that are administered directly

Exclusion for Consumer Products

Ordinary consumer products, such as window cleaners, household cleaners, and the like, are exempt from OSHA's Hazard Communication Standard, if their use in the workplace is the same as that of a typical consumer. For example, no MSDS would be required for a wood cleaning product that employees occasionally used to shine their office desks. However, if any employees frequently clean desks as part of their regular job duties, then an MSDS would be required for the product.

Exclusion of "Articles"

The exclusion for "articles" applies to any manufactured item (other than a fluid or particle) that:

•	does not expose users to hazardous chemicals during normal conditions of use (other than trace or minute amounts);

•	is formed to a specific shape or design during manufacture; and

•	is dependent at least partly on its shape or design for end use.

The following are three examples of items that OSHA generally regards as articles that do not require MSDSs:

•	adhesive tape

•	automobile tires

•	stainless steel tables

The following are three examples of items that do not qualify as articles, so that MSDSs are required:

•	metal ingots that melt under normal conditions of use

•	bricks used in construction (since crystalline silica is released when they are dry cut or drilled, a normal condition of use)

•	switches containing mercury that are installed during maintenance (since a certain percentage of the switches can be expected to break and release mercury during normal conditions of use)

Office Supplies

In a letter of interpretation, OSHA indicated that it considers most office products to be exempt from coverage under the Hazard Communication Standard, either as consumer products or as articles. Examples of such exempt products are pens, pencils, and adhesive tape. The exemption for some office products depends on how they are used. For example, an MSDS would not be required for a copier that an employee handles only occasionally. However, if the employee regularly services copiers as part of his or her job duties, then an MSDS would be required.

29 CFR 1910.1200


Sample MSDSs

A Material Safety Data Sheet (MSDS) is the document that must accompany every hazardous chemical that a manufacturer or importer of that chemical ships. It is the primary document in the Hazard Communication Standard (HCS) issued by OSHA.

This section contains two sample MSDSs. One is the official blank form as designed by OSHA. This form is not mandatory and manufacturers of hazardous substances may use any form they desire as long as it includes at least as much information as the OSHA-designed form.

Also included in this section is a sample MSDS that has been filled in with typical information found on an MSDS. The completed sample shows how the form can vary as long as it contains the necessary information.

This section contains Adobe Acrobat® documents. Simply click on one of the buttons below to open your Acrobat Reader® and the selected .pdf document. When you are done reviewing the MSDS forms, close Acrobat Reader or minimize it for later use in this guide.


How to Read and Understand an MSDS

The Material Safety Data Sheet (MSDS) is the primary document in hazard communication. OSHA standards require manufacturers and importers to provide an MSDS with each of the chemicals they ship. OSHA standards also require employers to have an MSDS for each hazardous chemical they use.

The importance of the MSDS can't be overstated. This form contains all known hazard and protection information on a hazardous chemical. The MSDS is a guide to safety.

OSHA has developed a sample MSDS form that many companies are using. Although the agency does not insist that everyone use OSHA's form, OSHA does expect all MSDSs to include the same basic information.

An MSDS should include information on the topics outlined below. The topics correspond with the blank OSHA MSDS form in the previous section. The completed sample is an example of how the form can vary as long as it contains the necessary information.

Section I - Identity

This section tells you the name of the chemical as it appears on the container label. The only time identity information is not provided is when the chemical name is a trade secret. Even in that situation, the MSDS must provide full hazard protection data.

The identity section also lists the name, address, and telephone number of the company that makes the chemical. An employer may contact the manufacturer for additional information.

Section II - Hazardous Ingredients / Identity Information

This section lists the hazardous parts of the chemical. The chemical is identified by its common and scientific names in this section. If it's a compound with more than one hazardous ingredient, the principal ingredients are listed here--usually by percentage.

This section also lists the exposure limits set by OSHA and other organizations. Both OSHA's Permissible Exposure Limit (PEL) and the Threshold Limit Value (TLV) set by the American Conference of Governmental Industrial Hygienists (ACGIH) are listed. These limits specify the maximum amount of exposure to the substance a worker can have based on an eight-hour workday. The OSHA limit is a legal one; ACGIH's limit is the stricter one and is only a recommendation. Both limits are usually given in parts per million (ppm) or milligrams per cubic meter (mg/m3).

Section II may also give a ceiling, or top exposure limit, which is the maximum allowable exposure at one time. Short-Term (15-minute) Exposure Limits (STEL) may be provided. There may also be information on whether the substance is "Immediately Dangerous to Life and Health" (IDLH). If the chemical is IDLH, the respiratory protection supplied by the employer must take this rate into consideration.

Section III - Physical / Chemical Characteristics

This section lists the chemical's normal state and helps define how the chemical will behave when it is released. For example, a chemical that is normally a liquid may evaporate quickly in a hot environment, thus increasing its risk as a fire hazard.

A chemical's physical characteristics could also affect its health hazards and the protection that an employee needs. A liquid may be dangerous if it splashes on skin, thus requiring that the employee wear protective clothing. But if the same chemical changes to a vapor, the chief risk may result from inhalation, requiring respiratory protection.

The chemical's normal appearance and odor are described in this section. Knowing the chemical's normal appearance, an employee can spot any changes or differences that could indicate trouble.

In addition to the normal state of the chemical, this section lists the circumstances, such as temperature, that could change that state.

•	Melting Point

The melting point is the temperature at which a solid changes to a liquid.

•	Boiling Point

The boiling point is the temperature at which a liquid changes to a gas.

•	Evaporation Rate

The evaporation rate is how long the chemical takes to evaporate. For example, butyl acetate has a relative evaporation rate of 1. A chemical with a higher number evaporates faster; one with a lower number evaporates slower.

•	Specific Gravity

The specific gravity is the density of the chemical compared to water, which has a relative value of 1. If the chemical's specific gravity is greater than 1, the chemical is heavier than water and will sink in water. If the chemical's specific gravity is less than 1, the chemical will float on water.

•	Vapor Density

The vapor density is the density of the chemical's vapor compared to air, which has the density of 1. If a chemical's vapor density is higher than 1, the vapor is heavier than air and will go to the floor. If the chemical's vapor density is lower than 1, the vapor will rise in the air.

•	Vapor Pressure

Vapor pressure measures how volatile a liquid is. Vapor pressure also measures how easily a liquid evaporates. The higher the number, the faster the liquid evaporates. This section of the MSDS also has a space that explains how much of the chemical will dissolve in water. The ability to dissolve is usually stated as a percentage or in parts per million (ppm).

Section IV - Fire and Explosion Hazard Data

This section states if the chemical has a potential to catch fire or explode.

Flash point is the lowest temperature at which a chemical's vapors are concentrated enough to ignite. The lower the flash point number, the more dangerous the material.

Example:

Gasoline's flash point is -45°F. Diesel fuel #2 has a flash point of +125°F.

This section contains the upper (UFL) and lower (LFL) flammable limits. Between these limits the substance is likely to ignite.

This section also lists the upper (UEL) and lower (LEL) explosive limits. These provide the minimum and maximum concentration of the chemical's vapor in the air for an explosion to occur. In addition, this section contains fire-fighting procedures and the extinguishing media.

Section V - Reactivity Data

Some substances are unstable. They can react with other substances or in specific kinds of conditions. This section lists the chemicals or conditions to avoid. Any hazardous by-products the chemical could generate are also listed, along with the hazards (such as toxic gases) that could be created if the chemical decomposes.

Section VI - Health Hazard Data

This section describes how the chemical gets into the human body and what effects it has on the body. The following are the usual methods of exposure:

•	inhalation or breathing

•	ingestion or swallowing

•	direct skin contact

This section also lists the health hazards the chemical poses:

•	acute: effects that show up immediately after exposure

•	chronic: effects that develop over time (usually serious)

•	carcinogenic: It notes whether the conclusion that the chemical causes cancer is based on findings of the International Agency for Research on Cancer (IARC) or National Toxicology Program (NTP). The section also states whether OSHA regulates the chemical for its cancer hazard.

This section of the MSDS also lists the symptoms of exposure.

Section VII - Precautions for Safe Handling and Use

This section provides the following types of information:

•	how to handle the chemical under normal conditions

•	how to handle a spill

•	what to use to clean up a spill

•	whether to evacuate immediately if there is a spill

•	how to dispose of waste chemical

Section VIII - Control Measures

This section describes the type of ventilation needed, such as:

•	local exhaust

•	mechanical exhaust

•	other

It also describes respiratory protection needed (if any).

This section contains OSHA's recommended protective devices and clothing.

SPECIAL PRECAUTIONS are also listed in this section.


Employer's Form to Request an MSDS

The following form letter acts to fulfill the requirement that a business request an MSDS from the manufacturer of a chemical if the MSDS did not accompany the delivery of the chemical. Use this form on company letterhead, inserting the information mentioned inside the brackets.

<date>

To:	<name and address of chemical manufacturer, importer, or

distributor>

Re:	Request for MSDS

As you are aware, OSHA requires employers to provide training to their employees concerning the hazards of chemicals and/or other hazardous materials.

To properly train our employees, we need a Material Safety Data Sheet (MSDS) on one or more of your products. Please send MSDSs for the following materials (chemicals):

<name of chemical>

<name of chemical>

<name of chemical>

Thank you for your prompt attention to help us maintain a proper level of safety for our employees.

If you have any questions, feel free to contact me at <phone number>.

Sincerely,

<signature>

<typed name>


Checklist of Required Information on an MSDS

Instructions: The Hazard Communication Standard requires that 13 items of information be included in a Material Safety Data Sheet (MSDS). The MSDS is provided to purchasers. There is no specified order for these items; they may be found anywhere on the MSDS. If the preparer of the MSDS did not find relevant information for any given item, he or she must mark the MSDS to indicate that no applicable information was found. This checklist will help you in determining the completeness of an MSDS. The checklist does not assess the accuracy of the information provided.

I.	Identity and Manufacturer Information

•	The identity used on the label (may be the same as the chemical or common name)

•	Name, address, and emergency phone number(s) of the manufacturer

•	Name of person who prepared the MSDS

•	Date MSDS was prepared

II.	Hazardous Ingredients / Identity Information

•	Hazardous ingredients

•	Chemical names/common names

•	OSHA PEL (permissible exposure limit)

•	ACGIH TLV (threshold limit value)

•	Other limits recommended

III.	Physical / Chemical Characteristics

•	Boiling point

•	Vapor pressure

•	Vapor density

•	Solubility in water

•	Appearance and color

•	Specific gravity

•	Melting point

•	Evaporation rate

IV.	Fire and Explosion Hazard Data

•	Flash point

•	Extinguishing media

•	Special fire-fighting procedures

•	Unusual fire and explosion hazards

•	Flammable limits

•	LEL (lower explosion limit)

•	UEL (upper explosion limit)

V.	Reactivity Data

•	Stability

•  Stable

•  Unstable

•	Conditions to avoid

•	Incompatibility

•	Hazardous decomposition or by-products

•	Hazardous polymerization

•  May occur

•  Will not occur

•	Conditions to avoid

VI.	Health Hazard Data

•	Route(s) of entry

•	Health hazards

•	Signs and symptoms of exposure

•	Medical conditions generally aggravated by exposure

•	Emergency first aid procedures

•	Carcinogenic?

•	OSHA-regulated?

VII.	Precautions for Safe Handling and Use

•	Steps to take if released or spilled

•	Waste disposal method

•	Precautions for handling and storing

•	Other precautions

VIII.	Control Measures

•	Respiratory protection (specific type)

•	Ventilation

•  Local exhaust

•  Special

•  Mechanical

•  Other

•	Protective gloves

•	Eye protection

•	Other protective clothing or equipment

•	Work/hygienic practices

Chemical: __________________________________________________

Date checked: ________________  Date on MSDS: _________________

MSDS checked by: ___________________________________________


Table of Contents

Sample Safety Plans

Introduction

Sample Emergency Action Plan

Overview

Plan Cover Sheet

Purpose

Location of Plan

Minimum Plan Requirements

Escape Procedures and Exit Routes

Critical Plant Operations

Accounting for Employees

Rescue and Medical Duties

Reporting Emergencies

Alarm Systems and Notification of Emergencies

Types of Evacuation

Training

Further Information

Sample Fire Safety Plan

Overview

Plan Cover Sheet

Purpose

Responsibility

Fire Exits

Portable Fire Extinguishers

Emergency Evacuation Planning

Fire Prevention Plan

Fire Suppression System

Sample General Safety Plan

Overview

Plan Cover Sheet

Purpose

Employee Compliance

Reporting Job-Related Injuries and Illnesses

General First Aid Practices

Key Safety Rules

Personal Hygiene and Sanitation

Safety Responsibilities of Supervisors

Employee Training

Bloodborne Pathogens

Rules for Toxic Vapors and Liquids

Materials Handling

Machine and Tool Maintenance and Inspection

Lock-Out/Tag-Out Procedures

Forklift Safety Rules

Back Injury Prevention

Personal Protective Equipment (PPE)

General Safety Rules for Offices

Disciplinary Policy

Disciplinary Penalties

Written Warnings

Disciplinary Notice to Employee

Certification of Employee

Sample Hazard Assessment Plan

Overview

Plan Cover Sheet

General Requirements

Controlling Hazards - In General

Assessment and Selection - In General

Guidelines for Selection and Use of PPE - In General

Eye and Face Protection - General Guidelines

Eye and Face Protection Selection Chart

Filter Lenses for Protection Against Radiant Energy

Eye and Face Protection - Selection

Head Protection - General Guidelines

Head Protection - Selection

Foot Protection - General Guidelines

Foot Protection - Selection

Hand Protection - General Guidelines

Hand Protection - Selection

Required Training - In General

Training Certification Record

Sample Hazard Communication Plan

Overview

Plan Cover Sheet

General Requirements

Purchases

Container Labeling

Material Safety Data Sheets (MSDSs)

Employee Information and Training

Inventory List of Hazardous Chemicals

Hazardous Chemicals Inventory Used

Non-Routine Tasks

Outside Contractors

Employee Training Guidelines


Introduction

Sample Safety Plans

OSHA requires that affected employers write and implement each of the following plans:

•	Emergency Action Plan

•	Fire Safety Plan

•	General Safety Plan

•	Hazard Assessment Plan

•	Hazard Communication Plan

This chapter provides sample plans that are designed to satisfy each of those requirements. These plans are available for an employer to copy and use in the workplace. An employer should modify these plans to meet any special needs and circumstances. If implemented, these plans may help the employer to comply with OSHA regulations.

In addition to the plans included in this chapter, OSHA standards require certain employers to implement other plans. Among the additional plans that are commonly required are a Bloodborne Pathogens Exposure Control Plan, a Forklift Safety Plan, a Lock-Out/Tag-Out Plan, and a Respiratory Protection Plan. Samples of these additional plans are available on Summers Press's Sample Safety Plans on CD, which includes all the plans found in this chapter plus several others. Call 800-743-6491 for information about our Sample Safety Plans for:

•	Bloodborne Pathogens Exposure Control Plan

•	Confined Space Plan

•	Contingency Plan (Community Right-to-Know Plan)

•	Fall Protection Plan for Precast Concrete Structures

•	Fall Protection Plan for Residential Construction

•	Forklift Safety Plan

•	General Health and Safety Plan for Construction

•	Integrated Contingency Plan (ICP)

•	Lock-Out/Tag-Out Plan

•	Respiratory Protection Plan

•	Waste Minimization Plan

•	Workplace Violence Prevention Plan

The buttons below represent the Sample Safety Plans that are available in the OSHA Compliance Guide. To view a copy of a plan, simply click on one of the buttons to open your Acrobat Reader® and select .pdf document. When you have finished viewing a plan, close Acrobat Reader® or minimize it for later use in this guide.


Sample Emergency Action Plan

The Occupational Safety and Health Administration (OSHA) requires employers to have an Emergency Action Plan. The purpose of the plan is to eliminate or minimize hazards to employees in the event of a fire or other emergency. This sample plan is designed to follow the OSHA requirements for most businesses.

This sample plan includes:

•	location of the plan

•	minimum plan requirements

•	designation of escape procedures and exit routes

•	procedures for critical plant operations

•	accounting for employees

•	rescue and medical duties

•	emergency reporting

•	alarm systems and notification of emergencies

•	types of evacuation in emergency circumstances

•	employee training

•	sources for employees to obtain further information about the plan

Employers Covered

Every employer must have an Emergency Action Plan. Employers with 10 or more employees must have written plans. Employers with fewer than 10 employees may have oral plans.

Legal Sources

This sample Emergency Action Plan follows the OSHA requirement for a written plan found in 29 CFR 1910.38 or 29 CFR 1926.35 (for the construction industry). Further information on alarm systems can be found in 29 CFR 1910.165, 29 CFR 1910.38(a)(3)(ii), and 29 CFR 1926.159 (for the construction industry).

These requirements are also discussed in the Digest (Chapter 6):

Emergency Action Plans

Related training requirements are also discussed in Chapter 7:

Alarm Systems

Emergency Evacuation


Sample Fire Safety Plan

OSHA standards require employers to provide proper exits, fire-fighting equipment, emergency plans, and employee training to prevent fire deaths and injuries in the workplace. When OSHA conducts workplace inspections, it checks to see whether employers are complying with standards for fire safety.

This sample plan includes:

•	building fire exit inspections

•	portable fire extinguisher rules

•	emergency evacuation plan procedures

•	fire prevention plan procedures

•	fire suppression plan procedures

Employers Covered

A variety of OSHA standards require employers to protect their employees from fire hazards. One aim of the regulations is to reduce the number of fires by limiting opportunities for ignition of flammable and combustible materials. A second purpose is to make sure that employees know how to escape harm in the event of fire. A third purpose is to require basic training regarding fire extinguishers, if some or all employees are allowed to use them.

In addition to provisions on fire prevention, this Sample Fire Safety Plan contains provisions for the evacuation of employees and for the use of fire extinguishers. The plan is intended to provide employers with an overall program for responding to fires, rather than merely preventing them. Options available to employers regarding the use of fire extinguishers are discussed below.

The mosaic of fire-fighting regulations generally gives employers three basic options on how to protect their employees from possible fires:

•	Option 1 - Immediately Evacuate All Employees: Instruct all employees to evacuate immediately in the event of fire. If this option is chosen:

-	do not provide fire extinguishers for employee use (or, if provided, designate them for use by non-employees only); and

-	develop and implement a Fire Prevention Plan (see subsection below).

•	Option 2 - Designate Certain Employees to Use Portable Fire Extinguishers: Designate and train certain employees to use fire extinguishers as part of the employer's Emergency Action Plan. All other employees must be instructed to immediately vacate the premises on the sounding of the fire alarm or signal.

•	Option 3 - Provide Portable Fire Extinguishers for Use by All Employees: Provide fire extinguishers and train all employees on using them to fight small fires. Employers must instruct their employees not to attempt to fight fires with an extinguisher unless they can safely do so. In addition, employers must train all of their employees on how to safely evacuate the premises in the event of fire.

Activities and materials that pose special fire dangers may impose additional requirements on employers. For example, for operations involving flammable or combustible liquids, explosives, or blasting agents, employers must provide employees with fire extinguishers and training on their proper usage. In addition, employers must comply with additional fire safety requirements for special fire hazards related to blasting agents, cranes, dipping and coating operations, explosives, flammable and combustible liquids, portable tanks, working platforms, and welding operations. Employers should modify this Sample Fire Safety Plan to meet the unique needs of their particular workplaces.

The Sample Fire Safety Plan does not address the detailed and rigorous requirements that apply to employers that have their own fire-fighting brigades. These brigades are rarely used, except by large industrial complexes.

Required Fire Prevention Plan

OSHA requires employers to have a written Fire Prevention Plan if the employers:

•	choose not to provide extinguishers; or

•	choose to designate fire extinguishers only for non-employee use.

An oral plan is allowed for employers with 10 or fewer employees.

The Fire Prevention Plan itself must address:

•	potential ignition sources;

•	effective housekeeping procedures;

•	the persons (or job titles) responsible for preventing the accumulation of flammable waste materials; and

•	the persons (or job titles) responsible for installing and maintaining fire suppression equipment.

Employers may also be required to have a Fire Prevention Plan if flammable materials, chemicals, explosives, or hazardous wastes are located in the workplace. Even if an employer is not required to have a Fire Prevention Plan, the adoption of such a plan is always a good idea. The easiest fire to extinguish is the one that never starts.

Legal Sources

This sample Fire Safety Plan follows OSHA requirements for a written plan found in 29 CFR 1910.38 and 1910.157.

These requirements are also discussed in the Digest (Chapter 6):

Emergency Action Plans

Exits

Fire Doors - No OSHA Standard

Fire Extinguishers

Fire Safety

Related training requirements are also discussed in Chapter 7:

Fire Brigades

Fire Extinguishers

Fire Safety


Sample General Safety Plan

All employees must follow safety rules in order for the rules to be effective. The following General Safety Plan contains a sample safety and disciplinary policy. An employer may need to modify or delete part of the plan to make it fit the company's needs and specific circumstances. The employer may also need to supplement the plan for the same reason.

In addition to disciplinary policies, this General Safety Plan emphasizes basic safety principles that may apply to many businesses. Among the provisions are:

•	general company policies

•	basic personal protective equipment (PPE) policies

•	general safety rules

•	sample office safety rules

•	accident reporting rules

•	general first aid practices

•	safety responsibilities of supervisors

•	disciplinary policy statement

•	sample disciplinary policy

This sample plan provides:

•	sample safety policies to provide a framework for a general safety plan

•	sample disciplinary policies to enforce safety rules, a sample disciplinary notice, and a sample certification

This plan's disciplinary provisions apply only to safety matters. It is presumed that an employer will have disciplinary procedures and penalties described elsewhere (i.e., in an employee handbook) for other concerns. An employer should make sure that this plan does not conflict with any material in its employee handbook. An employer should modify any provisions that do not fit its particular desires or needs.

In addition, this General Safety Plan is intended for at-will employees who have no contractual or other right to continued employment. The employer should modify this General Safety Plan (particularly the disciplinary and notice provisions) for employees whose possible discharge or discipline is restricted, such as those protected by collective bargaining agreements.

Employers Covered

All employers need to have a General Safety Plan. OSHA requires that all employers effectively enforce safety rules to implement OSHA standards. This requires a General Safety Plan as well as individual safety plans. In addition, effective enforcement requires that employees be subject to discipline and even discharge for failure to follow applicable rules and standards.

Related Plans and Requirements

This General Safety Plan is not designed as a substitute for specific plans that are required by OSHA, including:

•	Bloodborne Pathogens Exposure Control Plan

•	Emergency Action Plan

•	Fire Safety Plan

•	Forklift Safety Plan

•	Hazard Assessment Plan

•	Hazard Communication Plan

•	Lock-Out/Tag-Out Plan

•	Respiratory Protection Plan

These plans are available from Summers Press in its Sample Safety Plans on CD.

These requirements are also discussed in the Digest (Chapter 6):

Bloodborne Pathogens

Emergency Action Plans

Fines and Penalties, Classification and Assessment

Fire Safety

Forklift Operations

Hazard Assessment

Hazard Communication

Respiratory Protection

Workplace Security

Related training requirements are also discussed in Chapter 7:

Bloodborne Pathogens

Emergency Evacuation

Fire Safety

Forklift Operations

Hazard Communication

Respiratory Protection


Sample Hazard Assessment Plan

OSHA requires employers to assess their workplace to determine if any actual or potential hazards require the use of personal protective equipment (PPE). The regulations require that the employer identify hazards and verify the assessment in writing. OSHA requires employers to first eliminate or reduce (if elimination is not possible) hazards through engineering controls and administrative (work practice) controls before using PPE for hazard protection.

Employers must also:

•	select PPE to protect employees

•	require employees to use selected PPE

•	provide necessary training to employees

•	not use damaged or defective PPE

This sample plan includes:

•	general guidelines for hazard review and assessment

•	general guidelines for eye and face protection

•	general guidelines for head protection

•	general guidelines for foot protection

•	general guidelines for hand protection

•	a certification of hazard assessment

•	employee training and certification

Employers Covered

All employers are required to conduct a hazard assessment.

Related Plan

Every employer must also require employees to wear respirators when necessary to protect their health. Any employer whose employees must wear a respirator as a protective device is also required to develop and implement a separate respirator plan. A sample Respiratory Protection Plan is available from Summers Press in its Sample Safety Plans on CD.

Legal Sources

This sample Hazard Assessment Plan follows the OSHA requirement for a written hazard assessment found in 29 CFR 1910.132.

These requirements are also discussed in the Digest (Chapter 6):

Foot Protection

Hand Protection

Personal Protective Equipment (PPE)

Respiratory Protection


Sample Hazard Communication Plan

The Occupational Safety and Health Administration (OSHA) requires employers to develop a written plan to communicate with employees about the hazards of particular chemicals used in the workplace.

This sample plan includes:

•	container labeling procedures

•	Material Safety Data Sheet (MSDS) procedures

•	employee information and training guidelines

•	sample forms to be used as part of the plan

Information on how to read and understand an MSDS is located in Chapter 2. This information should also be included in the training material for the Hazard Communication Plan.

Employers Covered

Every employer that uses a hazardous material (any material that has or requires an MSDS) is covered.

OSHA has specific rules that apply to hazard communication at multi-employer sites, which are often present in the construction industry. In the case of multi-employer sites, the required hazard communication plan must include:

•	how employers will inform other employers in the same work area of hazardous substances to which their employees will be exposed

•	appropriate protective measures for warning employees of other employers of chemical hazards and for informing those employees of the MSDS access and labeling systems in use

OSHA Directive on Alternative Systems

Under an OSHA directive, employers may provide employees access to MSDSs through an alternative system, including use of the Internet, microfiche, computers, CDs, and fax machines. However, employers using these alternative electronic means must ensure that:

•	reliable devices are available in the workplace at all times to access the MSDSs;

•	workers are trained in use of the devices, including use of software; and

•	there is an adequate back-up system for rapid access to MSDSs during an emergency, including power outages, on-line access delays, etc.

In addition, employees must be able to access hard copies of the MSDSs. In medical emergencies, employers must be able to immediately provide copies of MSDSs to medical personnel.

Related Plan

Employers storing large quantities of hazardous materials, or excessive amounts of extremely hazardous substances, may also be subject to the contingency plan (known as the Community Right-to-Know) regulations of the Environmental Protection Agency. A sample Contingency Plan that follows the Community Right-to-Know regulations is available from Summers Press in its Sample Safety Plans on CD.

Legal Sources

This sample Hazard Communication Plan follows the OSHA requirement for a written plan found in 29 CFR 1910.1200 or 29 CFR 1926.59 (for the construction industry).

Hazard communication requirements are also discussed in Chapter 2.

Related training requirements are also discussed in Chapter 7, Hazard Communication.


Table of Contents

Reporting, Recordkeeping, and Posting

Introduction

Accident Reporting Requirements

Required Reporting

When to Report

Content of Report

Changes in the New Rule

Overview of Recordkeeping Requirements

Partially Exempt Employers

Required Forms

Permitted Alternative Forms

Determining a Recordable Injury or Illness

Required Employee Involvement

Location and Retention of Records

Access to Records

Major Revisions in OSHA's New Recordkeeping Rule

Flow Charts of Recordable Cases

Determining Recordable Cases in the New Federal 300 and 301 Logs

Element 1: Work-Relatedness

Presumption for the Work Environment

Injuries and Illnesses While Traveling

Injuries and Illnesses While Working at Home

Aggravation of Pre-Existing Conditions

Element 2: New Case

Element 3: Satisfying Recording Criteria

Days Away from Work

Restricted Work or Job Transfer

Medical Treatment Beyond First Aid

Loss of Consciousness

Diagnosis of Significant Injury or Illness

Special Requirements for Certain Conditions

Entering Recordable Cases in the 300 Log

Steps in Completing the 300 Log

Identifying Employees

Date, Place, and Brief Description

Classifying the Case's Seriousness

Calculating Days Away or Work Restrictions

Classifying the Case as an Injury or Illness

Injuries

Illnesses

Completing and Posting Form 300A

Completing the 301 Log

Form 300

Form 300 Description

Sample Form 300

Form 300A

Form 300A Description

Sample Form 300A

Optional Worksheet for Form 300A

Form 301

Form 301 Description

Sample Form 301

Partially Exempt Businesses

Posting Requirements

For Additional Information


Introduction

Reporting, Recordkeeping, and Posting

This chapter provides an overview of OSHA recordkeeping, posting, and reporting requirements. Understanding and following these OSHA regulations is important because employers are subject to substantial penalties for noncompliance.

Most businesses are subject to OSHA recordkeeping requirements. This chapter includes an in-depth discussion of which injuries and illnesses must be recorded. The discussion should help immensely with OSHA's practical recordkeeping requirements.

New Federal Recordkeeping Rule

OSHA adopted a new recordkeeping rule that generally took effect on January 1, 2002 (see Overview of Recordkeeping Requirements). However, OSHA agreed not to issue any citations for violations of the new regulations that occurred during the first 120 days after January 1, 2002. OSHA agreed to the 120-day moratorium to settle a lawsuit filed by the National Association of Manufacturers.

In addition, OSHA has delayed two controversial parts of the new rule until January 1, 2003, to review and possibly revise them:

•	the requirement that a Standard Threshold Shift of 10 decibels or more be recorded as a hearing loss; and

•	the creation of a specific definition and separate illness category on the 300 Log for "musculoskeletal disorders (MSDs)."

Hearing losses will continue to be recordable under OSHA's existing practice (i.e., if they involve a standard threshold shift in either ear of 25 decibels or more at 2,000, 3,000, and 4,000 hertz). MSDs will be recordable as either injuries or illnesses if they meet the new rule's general three-part test (see Determining Recordable Cases in the New Federal 300 and 301 Logs).

Applicable Forms

Copies of the following forms, along with instructions on their use, are found in this chapter:

•	OSHA 300 Log

•	OSHA Form 300A

•	OSHA 301 Log

Failure to properly maintain OSHA recordkeeping logs is one of the most common violations of OSHA standards.

OSHA Recordkeeping Software

OSHA recordkeeping compliance is now easier than ever with the OSHA Recordkeeping Software. This Windows-based software greatly simplifies maintaining OSHA records. It produces OSHA-approved 300, 300A, and 301 Logs. Review it risk-free for 30 days. If it is not helpful and easy to use, simply return it with no further obligation.

Call Summers Press at 866-743-9911 for further information.


Accident Reporting Requirements

Required Reporting

All employers must follow OSHA accident reporting requirements. Even if a business is exempt from OSHA recordkeeping requirements, it must report accidents that meet the criteria below. Employers in states with OSHA-approved plans may have stricter requirements than those outlined below (see Chapter 8).

When to Report

Employers must report orally any work-related accident within eight hours of the event or when the employer learns of the accident if it results in:

•	death; or

•	three or more employees being admitted to the hospital.

This type of accident must be reported to the nearest OSHA area office (see Directories). The report can be made by telephone or in person. Employers may use OSHA's toll-free hotline for reporting workplace safety or health emergencies (800-321-OSHA). The toll-free hotline may be the only option for timely reporting if an accident occurs during the weekend or any other time the OSHA office is closed. Employers cannot report by e-mail to satisfy OSHA's accident reporting requirements.

This rule applies to fatalities and hospitalizations that occur within 30 days of a work-related incident.

Content of Report

The report must include the name of the establishment, the time and location of the incident, the number of fatalities or hospitalized employees, the name of the contact person, a phone number, and a brief description of the incident.

Changes in the New Rule

Under the new recordkeeping rule, OSHA excludes fatalities or multiple hospitalization incidents from reporting requirements if they involve:

•	motor vehicle accidents on public streets or highways (unless occurring in a construction zone); or

•	a commercial airplane, train, subway, or bus accident.

However, the new federal rule does not eliminate the requirement to enter injuries from these transportation accidents on the appropriate logs (see Overview of Recordkeeping Requirements).


Overview of Recordkeeping Requirements

On January 1, 2002, OSHA's new recordkeeping rule took effect. The rule replaces the OSHA 200 Log with the OSHA 300 Log and the OSHA 101 Log with the OSHA 301 Log. In addition, the rule creates a new Form 300A for posting information about job-related injuries and illnesses for a calendar year. The Form 300A is to be used beginning in calendar year 2003 (see Completing and Posting Form 300A).

In creating the new logs, OSHA has made a number of important changes. These include revisions to applicable exemptions and recording criteria, as well as the creation of strict new regulations to protect employee privacy (see Major Revisions in OSHA's New Recordkeeping Rule for an overview of the major revisions to the Recordkeeping Standard).

Unless employers are partially exempt (see below), they must comply with OSHA's recordkeeping requirements. Employers should note that they are not admitting fault for workers' compensation or insurance purposes merely by recording an injury or illness in OSHA's 300 and 301 Logs.

Partially Exempt Employers

"Partially exempt" employers do not have to complete records of injuries or illnesses (OSHA Forms 300, 300A, and 301), but still must report fatalities and serious accidents (see Accident Reporting Requirements) and display an OSHA poster (see Posting Requirements). An employer is partially exempt under OSHA's new recordkeeping requirements if it fits into one of two categories:

•	Small Business Exemption: Has 10 or fewer employees in the entire company at all times during the last calendar year (same as the previous rule); or

•	Low-Hazard SIC Code Exemption: Has a business establishment classified in designated retail, service, finance, insurance, or real estate industries.

A list of standard industrial classification (SIC) code exemptions under the new standard is provided in Partially Exempt Businesses. Many of the designated codes have changed from the previous rule. In addition, it is important to note that the SIC code exemption is based on "business establishment." A company may have different establishments that engage in different SIC code activities. An establishment with an SIC code exemption would not have to keep OSHA Forms 300, 300A, and 301, but all of a company's non-exempt establishments would have to complete the logs.

Despite being partially exempt, an employer must keep the OSHA logs on written request from the Bureau of Labor Statistics, OSHA, or an authorized state agency. In addition, certain states and the District of Columbia have OSHA-approved plans that may restrict or eliminate the exemptions for small employers or low-hazard SIC code businesses (see State OSHA Plans).

Required Forms

Under the new rules, three forms (or their equivalents) are required for OSHA recordkeeping:

•	OSHA No. 300: An annual log and summary of occupational injuries and illnesses that records the occurrence, extent, and outcome of cases (see Form 300).

•	OSHA No. 300A: A summary of job-related accidents or illnesses for a calendar year. Beginning in calendar year 2003, it must be completed and posted in place of the old 200 Log (see Form 300A).

•	OSHA No. 301: A form with additional details on each case recorded on the OSHA No. 300 Form (see Form 301).

Permitted Alternative Forms

OSHA permits employers to use forms equivalent to Forms 300, 300A, and 301 if the alternative forms:

•	have the same information;

•	are readable and understandable; and

•	are completed using the same instructions as the forms they replace.

The rule specifically provides that employers may keep OSHA's required records on computer if they are accessible (see Access to Records). Employers that are interested in computerized recordkeeping should consider OSHA Recordkeeping Software, which is published by Summers Press.

Determining a Recordable Injury or Illness

Assuming that an employer is not exempt, an injury or illness must satisfy each of the following three elements to be recordable:

•	be work-related

•	qualify as a new case

•	be serious enough to satisfy at least one of the following recording criteria:

-	death

-	days away from work

-	restrictions on work or transfer to another job

-	medical treatment beyond first aid

-	loss of consciousness

-	a significant injury or illness diagnosed by a doctor or other health care professional

-	specific thresholds for needlestick/sharps injuries, tuberculosis cases, or required medical removal under OSHA standards

The flow charts in this chapter summarize the basic steps to be taken for determining a case's recordability (see Flow Charts of Recordable Cases). In addition, Determining Recordable Cases in the New Federal 300 and 301 Logs provides a step-by-step set of questions and instructions for verifying whether a particular injury or illness is recordable. A recordable injury or illness must be entered on both the 300 and 301 Logs (see Entering Recordable Cases in the 300 Log and Completing the 301 Log for instructions on completing these logs).

Required Employee Involvement

To encourage employee involvement and improve the accuracy of the recordkeeping system, employers must:

•	inform each employee of how he or she is to report an injury or illness to the employer; and

•	provide employees and their representatives with limited access to the records (see Access to Records).


Location and Retention of Records

Generally, each establishment or worksite should maintain its own 300 Log and other required records at that establishment. However, the 300 Log may be maintained at the employer's headquarters or other central location if the employer is capable of:

•	sending information from other establishments to the central location to complete the log within seven calendar days after notice of the occurrence of a recordable case; and

•	transmitting records from the central location to other establishments so that employees, former employees, and government officials may obtain access to certain records in a timely fashion (see Access to Records).

Retention Requirements

Records must be kept in each establishment for five years. These records include OSHA Forms 300, 300A, and 301, and the privacy case list, if applicable (see Entering Recordable Cases in the 300 Log). The five-year period is measured from the last day of the year to which the records relate.


Access to Records

Except on OSHA's specific request, employers are not required to submit their recordkeeping forms (i.e., Forms 300, 300A, and 301) to the agency. However, the forms must be available for inspection by both OSHA and affected employees as follows:

•	Authorized Government Representatives: Provide copies within four business hours.

•	Employees, Former Employees, and Their Representatives: Provide access to:

-	copies of current or stored 300 Logs by the end of the next business day

-	copies of an OSHA 301 report involving the current or former employee by the end of the next business day (to employees, former employees, and designated personal representatives; excludes collective bargaining agents)

-	copies of an establishment's OSHA 301 reports to an employee's authorized collective bargaining agent within seven calendar days (Provide only information from the section "Tell us about the case" and remove the rest of the data.)

For additional information on how to deal with "privacy cases," see Entering Recordable Cases in the 300 Log. For a discussion of employee and OSHA access to medical and exposure records, see Medical Records, Access and Retention.


Major Revisions in OSHA's New Recordkeeping Rule

In changing its recordkeeping rule and forms, OSHA had two important objectives. First, the relevant requirements are now clearly spelled out in the rule itself. Under the former system, employers had to be familiar with OSHA guidelines, interpretive letters, and other extraneous materials to record injuries and illnesses effectively. Second, the new rule and forms change many requirements in order to simplify the task for employers and improve the information available to OSHA.

Among the most important changes and provisions of the new rule and new forms (OSHA Forms 300, 300A, and 301) are the following:

•	Changes in Retail Business Exemption: Under the new rule, OSHA has adopted more precise SIC codes for determining business establishments that qualify for this exemption. Employees in 17 formerly exempt industries are covered, and employees in 16 formerly covered industries are exempted. A list of the new exemptions may be found in Partially Exempt Businesses.

•	Equal Treatment of Injuries and Illnesses: In determining what should be recorded, the new rule treats injuries and illnesses the same. Under the old system, all work-related illnesses were recordable, but occupational injuries qualified only if they involved medical treatment beyond first aid, work restrictions, lost workdays, etc.

•	Determining Work-Relatedness: Several changes apply in determining work-relatedness of an injury or illness:

-	An aggravation of a pre-existing condition qualifies as work-related only if it is significant.

-	Specific exceptions to the "geographic presumption" (i.e., the presumption of work-relatedness applicable to injuries in the work environment) are set forth in the rule itself.

-	Specific provisions detail how to determine recordability of an injury that occurs while an employee is working at home or traveling.

•	Counting Days Away from Work:

-	This is done based on calendar days, rather than scheduled workdays.

-	A 180-day cap applies.

-	The employer must count days when an employee works contrary to professional medical advice.

•	Determining Medical Treatment Versus First Aid: This is simplified and clarified as follows:

-	A list of 14 categories of activities (e.g., using hot or cold therapy, using eye patches) are considered first aid regardless of whether a health care professional or lay person performed them.

-	Diagnostic procedures and visits to a physician or other health care professional for observation or counseling are not considered medical treatment.

•	Time for Recording Injury or Illness on Logs: The employer has to record the injury or illness on the OSHA 300 and 301 Logs within seven calendar days (formerly six working days) of receiving information that a recordable injury or illness has occurred.

•	General Rule of Privacy Protection: Employers generally have to remove or hide employees' names and other personal identifiers whenever the OSHA 300 and 301 Logs are disclosed to persons other than government representatives or employees, former employees, or their authorized representatives. Exceptions allow disclosure of the identifying information in cases of workers' compensation and in cases involving safety consultants and auditors hired by the employer. (Note: Except in privacy concern cases, employers cannot remove personal identifiers when disclosing information on the 300 and 301 Logs to employees, former employees, and government representatives.)

•	Special Rule for "Privacy Concern Cases": To protect employee privacy, the new rule would prohibit an employer from entering the name of an employee on the 300 Log in certain types of especially sensitive cases (e.g., sexual assaults, needlestick injuries).

•	Annual Posting of Form 300A: Beginning in calendar year 2003, this summary must be posted each year from February 1 until April 30.

•	Employee Involvement: Under the revised rules, employers have an affirmative duty to encourage employee participation by:

-	setting up a way for employees to report work-related injuries and illnesses; and

-	informing each employee of how to report work-related injuries and illnesses.

•	Employee Protection: A specific provision has been added to prohibit discrimination against employees who request access to OSHA records or report a work-related injury or fatality.


Flow Charts of Recordable Cases

The following flow charts outline the basic steps to determine if a workplace injury or illness must be recorded on the OSHA 300 and 301 Logs. Flow Chart 1 diagrams the steps in determining the recordability of cases that don't involve pre-existing conditions. Flow Chart 2 diagrams the steps for cases with pre-existing conditions. Information on both kinds of cases is discussed in much greater detail in Determining Recordable Cases in the New Federal 300 and 301 Logs.

The buttons below represent the flow charts that are available in the OSHA Compliance Guide. To view a copy of a chart, simply click on one of the buttons to open your Acrobat Reader® and select .pdf document. When you have finished viewing the chart, close Acrobat Reader® or minimize it for later use in this guide.


Determining Recordable Cases in the New Federal 300 and 301 Logs

An illness or injury must satisfy three distinct elements to be recordable: (1) work-relatedness, (2) newness, and (3) satisfaction of specific recording criteria (i.e., threshold of seriousness).


Element 1: Work-Relatedness

Question 1

Did an event or exposure in the work environment (anywhere employees are working and present as a condition of employment) either:

(a)	cause or contribute to the resulting condition; or

(b)	significantly aggravate a pre-existing illness or injury?

OSHA defines "work environment" to include not only physical locations, but also equipment or materials used by employees during the course of their work.

A "yes" answer to either (a) or (b) of Question 1 would mean that the event is work-related. To determine work-relatedness (other than for a pre-existing condition), proceed to Questions 2 and 3 for employees hurt in the work environment, Questions 4 and 5 for employees hurt while traveling, and Question 6 for employees hurt at home. To determine the work-relatedness of an incident that involves the aggravation or worsening of any pre-existing condition, proceed to Questions 7 and 8.

Assuming that al injury or illness is work-related, the employer still must proceed to determine two more elements of recordability: (1) whether it is a new case (Questions 9 and 10) and (2) whether it is serious enough to record (Questions 11 - 15).

Presumption for the Work Environment

Any injury or illness that occurs in the work environment is presumed to be work-related. This means that an injury or illness arising in the work environment is regarded as work-related unless a specific exception applies as outlined in Question 3.

OSHA has observed that the work environment primarily consists of:

•	the employer's premises; and

•	other locations where the employees are:

-	engaged in work-related activities; or

-	present as a condition of their employment.

Employers also should note that company parking lots generally qualify as part of the work environment. Injuries suffered there are considered work-related, except if workers are hurt while commuting to and from work (see Question 3(h)).

Question 2

Did the injury or illness occur in the work environment?

A "yes" answer requires the employer to regard any injury or illness as work-related unless it meets a specific exception in Question 3.

If the answer to Question 2 is "no," there is no presumption of work-relatedness. Generally, this means that the injury or illness is not work-related and not recordable. However, injuries that occur while an employee is traveling or working at home may be work-related. To determine the recordability of these cases, the employer should proceed to Questions 4 - 6.

Question 3

Even though the injury or illness arose in the work environment, do any of the following subsections (a) - (j) apply:

(a)	it occurred while the employee was present as a member of the general public (rather than as an employee)?

(b)	it involved signs or symptoms that merely surfaced at work, but were solely caused by a non-work-related event or exposure?

(c)	it resulted solely from voluntary participation in:

-	a wellness program; or

-	a medical, fitness, or recreational activity (e.g., blood donation, physical examination, flu shot, exercise class, baseball)?

(d)	it resulted solely from an employee eating or drinking food or drink for personal consumption (e.g., choking on a sandwich)?

(Note: Exception (d) to recordability does not apply to food contaminated by workplace chemicals such as lead or to food poisoning caused by employer-supplied food.)

(e)	it resulted solely from the employee doing personal tasks (unrelated to employment) outside of assigned working hours?

(f)	it resulted solely from personal grooming or self-medication for a non-work-related condition?

(g)	it was intentionally self-inflicted?

(h)	it occurred in a motor vehicle accident on a company parking lot or company access road as the employee was commuting to or from work?

(Note: Exception (h) to recordability does not apply to other incidents in company parking lots, such as slips and falls and motor vehicle accidents while an employee is conducting company business.)

(i)	it involved the common cold or flu?

(Note: Contagious diseases such as tuberculosis, hepatitis A, and plague are work-related if the employee becomes infected at work.)

(j)	it involved a mental illness (unless the employee voluntarily provides a physician or other professional opinion that it is work-related, in which case the exception does not apply)?

If the answer to any of subsections (a) - (j) of Question 3 is "yes," the injury or illness is neither work-related nor recordable, even though it occurred in the work environment.

If the answer to all of subsections (a) - (j) of Question 3 is "no," the injury or illness is work-related. Proceed to Questions 9 and 10 and Questions 11 - 15 to determine if a new case is involved and if it is serious enough to be recordable.

Injuries and Illnesses While Traveling

Injuries and illnesses may occur to an employee who travels on the employer's behalf. Special rules determine the recordability of injuries or illnesses in these cases.

Question 4

At the time of the injury or illness, was the employee who was on travel status engaged in work activities in the interest of the employer, such as:

(a)	conducting job tasks;

(b)	traveling to and from business contacts;

(c)	entertaining or being entertained at the direction of the employer to transact, discuss, or promote business; or

(d)	conducting other activities on the employer's behalf?

If the answer to any of subsections (a) - (d) to Question 4 is "yes," the injury generally is work-related unless it meets one of the specific exceptions in Question 5.

Question 5

Has the employee who is on travel status done any of the following:

(a)	established a "home away from home" (i.e., checked into a hotel, motel, or other temporary residence for one or more days) and become injured while not engaged in work-related activity?

(b)	established a "home away from home" and become injured while commuting between the temporary residence and the job location?

(c)	become injured while on a personal detour from a reasonably direct route of travel (i.e., has the employee taken a "side trip" for personal pleasure or other personal reasons)?

If the answer to all of subsections (a) - (c) of Question 5 is "no," the case is work-related and recordable. Proceed to determine if it is a new case (Questions 9 and 10) and serious enough to be recordable (Questions 11 - 15).

If the answer to any of subsections (a), (b), or (c) of Question 5 is "yes," the injury or illness is not work-related and not recordable.

Injuries and Illnesses While Working at Home

Question 6

Do all of the following conditions apply to an employee who became ill or injured at home:

(a)	was the employee working at home or at home office at the time he or she became injured or ill;

(b)	was the employee being paid or compensated for the work; and

(c)	was the injury or illness directly related to performing the work, rather than to the general home environment?

If the answer to all of subsections (a) - (c) of Question 6 is "yes," the case is work-related and recordable, even though it occurred at home. Proceed to determine if it is a new case (Questions 9 and 10) and serious enough to be recordable (Questions 11 - 15).

For an injury or illness that occurs at home, if the answer to any of subsections (a) - (c) of Question 6 is "no," the case is not work-related and not recordable.

The most difficult part of the test in Question 6 is determining if an injury or illness is directly related to performing the work. OSHA considers the following as examples of injuries to an employee directly related to work at home:

•	dropping a box of work documents and hurting his or her foot

•	puncturing a finger while using a sewing machine at home to do garment work for the employer

OSHA regards the following as examples of injuries to an employee not directly related to the work at home:

•	tripping on the family dog while running to answer a work phone call

•	being electrocuted because of faulty home wiring

Aggravation of Pre-Existing Conditions

The aggravation or worsening of pre-existing conditions is examined differently than other injuries and illnesses. An employer should answer Questions 7 and 8 to determine if a pre-existing condition is involved.

Question 7

Was the original pre-existing condition caused solely by a non-work-related event or exposure that occurred outside of the work environment?

(Note: "Non-work-related" and "outside of the work environment" refer to the current employer only. Thus, pre-existing conditions may include injuries or illnesses that an employee suffered while working for another employer.)

If the answer to Question 7 is "no," then the injury or illness does not involve a pre-existing condition. Answer Questions 2 - 6 to determine the work-relatedness of the injury or illness.

If the answer to Question 7 is "yes," the injury or illness qualifies as a pre-existing condition. Proceed to Question 8 to determine if the injury or illness was significantly aggravated or worsened by a work-related event or exposure.

Question 8

Did an event or exposure in the work environment cause any of the following to occur to an employee with a pre-existing condition:

(a)	death? (The pre-existing condition must not have been likely to cause the death in the absence of the event or exposure.)

(b)	loss of consciousness? (The pre-existing condition must not have been likely to cause this result in the absence of the event or exposure.)

(c)	one or more days:

-	away from work;

-	of restricted work; or

-	of job transfer?

(d)	medical treatment if it was not needed before the event or exposure?

(e)	a change in medical treatment?

If the answer to any of subsections (a) - (e) of Question 8 is "yes," the aggravation of the pre-existing condition should be regarded as significant and qualifies as work-related. Proceed to determine if it is a new case (Questions 9 and 10) and serious enough to be recordable (Questions 11 - 15).

If the answer to all of subsections (a) - (e) of Question 8 is "no," the aggravation of the pre-existing condition is not significant and not recordable.


Element 2 - New Case

In addition to being work-related (Questions 1 - 8), an injury or illness must qualify as a "new case" to be recordable.

Question 9

Before this injury or illness, had the employee previously experienced a recorded injury or illness of the same type that affects the same part of the body?

If the answer to Question 9 is "no," the injury or illness qualifies as a new case. Proceed to determine if it is serious enough to be recordable (Questions 11 - 15). If the answer to Question 9 is "yes," proceed to Question 10.

Question 10

Had the employee completely recovered from the previously recorded injury or illness, whose symptoms reappeared because of an event or exposure of the work environment?

If the answer to Question 10 is "yes," the injury or illness qualifies as a new case. Proceed to determine if it is serious enough to be recordable (Questions 11 - 15). If the answer to Question 10 is "no," the injury or illness does not involve a new case and is NOT recordable. However, the employer may have to line out the original entry and write a new entry to update the information (see Entering Recordable Cases in the 300 Log).

In the case of a chronic work-related illness (e.g., asbestosis, occupational cancer, silicosis), employees may experience frequent recurrences of the disease's signs or symptoms. However, in the revised recordkeeping rule, OSHA indicates that these cases generally need to be recorded only once. On the other hand, OSHA also cites the examples of occupational asthma and contact dermatitis as illnesses in which different episodes should generally be treated as new cases if caused by an event or exposure in the workplace.

An employer is not required to seek a physician's advice about whether an injury or illness is a new case or merely a recurrence of an old case. But if the employer does consult with a doctor or other health care professional, the employer must follow the recommendation unless it receives two or more conflicting professional opinions. In that event, the employer may follow the professional advice that it regards as most authoritative.


Element 3 - Satisfying Recording Criteria

An injury or illness that qualifies as both work-related and as a new case still must reach a certain level of seriousness to be recordable. To reach this level, it must satisfy one of seven different conditions, which are outlined in Question 11 below.

Question 11

Does the injury or illness involve any of the following:

(a)	death?

(b)	days away from work?

(c)	days of restricted work or job transfer (see Question 12 and related subsection below)?

(d)	medical treatment beyond first aid (see Question 13 and related subsection below)?

(e)	loss of consciousness (see related subsection below)?

(f)	significant injury or illness diagnosed by a physician or other health care professional (see related subsection below)?

(g)	needlestick or sharp injuries, hearing cases, tuberculosis cases, or medical removal cases under OSHA standards (see related subsection below)?

If the answer to any of subsections (a) - (g) of Question 11 is "yes," a new work-related injury or illness must be recorded.

Days Away from Work

In counting days away from work for an injury or illness, the employer should not include the day on which the injury occurred or the illness began. This means that if the employee did not miss any work except for the day of the injury or illness, the case generally is not recordable under the days away from work criterion.

Sometimes employees will come to work in violation of a recommendation from a doctor or other health care professional. OSHA generally requires that such a day be treated as a day away from work even though the employee actually comes to work. If the employer receives two or more conflicting professional recommendations regarding the employee's condition, the employer may make a decision as to which is most authoritative.

Restricted Work or Job Transfer

As with days away from work, the employer should not include the day on which the injury occurred or the illness began. This means that if the employee did not receive any job restrictions or a work transfer except for the day of the injury or illness, the case generally is not recordable.

Question 12

Does the employee's injury or illness result in at least one day (other than the day of injury or illness) of the following:

(a)	a job transfer by the employer, or a professional recommendation for such a job transfer?

(b)	work restrictions or recommended work restrictions because the employee:

-	cannot perform (or receives a health professional's recommendation not to perform) one or more of the job's "routine functions" (i.e., activities regularly performed at least once a week)?

-	cannot work (or receives a professional recommendation not to work) the full workday that he or she would have otherwise worked?

If the answer is "yes" to either subsection (a) or (b) of Question 11, or both, the injury or illness is recordable.

Medical Treatment Beyond First Aid

A new work-related injury or illness must always be recorded if it involves:

•	medical treatment beyond first aid; or

•	a medical visit for any purpose beyond:

-	mere counseling and observation;

-	mere conducting of diagnostic procedures; or

-	mere first aid.

Under the revised rule, OSHA has created an exhaustive list of treatments that are to be regarded as first aid, whether they are administered by a health care professional or a lay person. No actions other than those listed below are to be considered first aid.

Question 13

Does the employee's treatment involve only the following:

(a)	nonprescription drugs at nonprescription strength;

(b)	tetanus immunizations (other immunizations such as vaccines for hepatitis B or rabies are regarded as medical treatment);

(c)	cleaning, flushing, or soaking of wounds on the surface of the skin;

(d)	Band-Aids™, bandages, or butterfly strips (sutures, staples, and other closing devices for wounds are regarded as medical treatment);

(e)	hot or cold therapy;

(f)	non-rigid means of support such as elastic bandages and wraps;

(g)	temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back board);

(h)	drilling of a fingernail or toenail to relieve pressure or draining of fluid from a blister;

(i)	eye patches;

(j)	removal of foreign bodies from the eye using only irrigation or a cotton swab;

(k)	removal of splinters or foreign material outside the eye by using:

-	irrigation;

-	tweezers;

-	cotton swabs; or

-	other simple means;

(l)	finger guards

(m)	massages (physical therapy and chiropractic treatment are not considered massage); or

(n)	relief of heat stress by drinking fluids?

If the answer to Question 13 is "yes," the injury or illness does not involve medical treatment and is not recordable.

In addition, as discussed in Question 14, under very limited circumstances an employee may visit a physician or other health care professional for purposes other than first aid without prompting the requirement to record the work-related injury or illness.

Question 14

As a result of the injury or illness, has the employee received no medical attention other than the following:

(a)	first aid (see Question 13);

(b)	visiting a physician or other health care professional solely for observation or counseling; or

(c)	undergoing diagnostic procedures, such as x-rays and blood tests (also includes prescription drugs used solely for diagnostic purposes, e.g., eye drops for pupil dilation)?

If the answer to Question 14 is "yes," the injury or illness is not recordable.

Loss of Consciousness

If a work-related injury or illness leads to loss of consciousness, it is always recordable. This is true no matter how brief the period of unconsciousness.

Diagnosis of Significant Injury or Illness

This is a catchall category designed to capture significant injuries and illnesses that:

•	are diagnosed by a physician or other health care professional; and

•	do not fit any of the other recording criteria (lost workdays, restricted work, loss of consciousness, etc.).

As examples of cases that may fit this category, OSHA cites punctured eardrums and fractured toes or ribs. These injuries may require neither medical treatment nor work restrictions, even though they are severe enough to justify being recorded.

In addition, OSHA cites the example of progressive diseases such as silicosis, byssinosis, and some types of cancer as fitting this category. On diagnosis, none of these severe illnesses may require immediate medical treatment or work restrictions. However, because these illnesses are significant, they should be recorded as soon as the employer is aware of the diagnosis by a health care professional.

Special Requirements for Certain Conditions

Several specific work-related conditions must be recorded whenever certain thresholds are met.

Question 15

Does the work-related injury or illness involve any of the following:

(a)	injuries from needlesticks or sharps contaminated with another person's blood or other potentially infectious materials?

(b)	any case for which OSHA health standards require the employee's removal from the workplace for medical reasons?

(c)	any confirmed case of tuberculosis (TB) infection after exposure to a known case of active TB?

If the answer to any of subsections (a) - (c) of Question 15 is "yes," the condition also must be recorded.


Entering Recordable Cases in the 300 Log

The employer must enter a recordable case on the 300 Log within seven calendar days after notice of the injury or illness. To determine if an injury or illness is in fact recordable, see Flow Charts of Recordable Cases and Determining Recordable Cases in the New Federal 300 and 301 Log s.

A copy of the 300 Log may be found in Form 300.

Steps in Completing the 300 Log

To fill out the 300 Log for a recordable injury or illness, the employer must complete several steps:

•	fill in the employee name unless a privacy case is involved

•	identify all of the following with respect to the accident:

-	date of occurrence

-	place of occurrence

-	brief injury description

•	classify the seriousness of the case

•	identify the number of days away from work or on job transfer or restriction

•	identify the case as an injury or illness and check the appropriate category for any illness

Identifying Employees

Normally, employers must provide the name of the injured or ill employee on the 300 and 301 Logs. However, in a major policy shift, OSHA's revised recordkeeping rule prohibits the identification of the employee's name in any privacy concern case that involves one or more of the following:

•	an intimate body part or the reproductive system

•	sexual assault

•	mental illness

•	HIV infection, hepatitis, or tuberculosis

•	needlestick or sharps injuries involving blood or other potentially infectious materials

•	other illnesses in which the employee independently and voluntarily requests that his or her name not be entered on the log

In any of the above cases, the employer must enter "privacy case" in the area designated for the employee's name on the 300 and 301 Logs. In addition, the employer must keep a separate privacy list containing the employees' names and case numbers for all privacy cases.

Date, Place, and Brief Description

The 300 Log requires employers to briefly describe the injury or illness and to specify the date and place of its occurrence. These sections are basically self-explanatory. However, they become more complicated in privacy cases, where the employee's name must be omitted.

In privacy concern cases, the employer has the discretion (but not the obligation as with the employee's name) to omit additional information. To do so, the employer must reasonably believe that nondisclosure is necessary to protect the employee. For example, the employer may wish to omit the department in which the employee works or the location of the injury from the log if disclosure of that information would make it possible to identify the victim.

The employer's discretion to withhold additional information in a privacy case is not unlimited. In exercising its discretion, the employer must enter enough information on the 300 Log to identify the cause and severity of the injury or illness.

Classifying the Case's Seriousness

The next step in recording an injury or illness is to classify the seriousness of the case. The employer must check the most serious outcome for each case from four OSHA categories, which are listed below:

•	Most Serious: Death

•	Second in Seriousness: Days away from work

•	Third in Seriousness: Job transfer or restriction

•	Least Serious: Other recordable

If the outcome or extent of an injury or illness changes after the case has been recorded, the employer should line out or white out the original entry and write the new entry where it belongs.

Calculating Days Away or Work Restrictions

The employer must calculate the days away from work and the days on restricted work or on job transfer. In making these calculations, an employer should follow these rules:

•	Exclude the Day of Injury: Don't include the day on which the injury occurred or that the illness began.

•	Count Calendar Days for Days Away from Work: Count calendar days, not scheduled workdays.

•	Use "Routine Job Functions" Test for Restricted Workdays: Consider an employee to be on restricted work if:

-	the employee is unable to perform one or more routine job functions;

-	the employee is unable to work a full workday that he or she was otherwise scheduled to work; or

-	a physician or other licensed health care professional recommends against working a full workday or performing one or more routine job functions.

•	Consider Both Days Away and Restricted Work: Enter the total days for each category (up to the 180-day combined cap) if a single case involves missed workdays and restricted workdays.

•	Apply 180-Day Cap: Enter the number 180 once total days off work or on restricted activity (either individually or in combination) reaches 180.

Classifying the Case as an Injury or Illness

The distinction in recording injuries and illnesses has been eliminated in the new 300 and 301 Logs. Like injuries, illnesses under the revised recordkeeping rule must meet certain levels of seriousness to be recordable. However, OSHA still requires the employer to classify each case as either an injury or an illness on the new logs.

Injuries

OSHA defines an injury as any wound or damage to the body resulting from an event in the work environment. The basic idea behind an injury is that a single discrete incident can be pinpointed as the cause of the affliction. OSHA gives the following as examples of injuries: a cut, puncture, laceration, abrasion, fracture, bruise, contusion, chipped tooth, amputation, insect bite, and electrocution. Sprain and strain injuries to muscles, joints, and connective tissues are classified as injuries when they result from a slip, trip, fall, or other similar accident.

Illnesses

Unlike injuries, illnesses often develop over some period of time, rather than occurring at one brief moment. However, some illnesses, such as carbon monoxide poisoning and sunstroke, may occur relatively suddenly. OSHA identifies four categories of illnesses:

•	Skin Diseases or Disorders:

-	Include problems that involve the worker's skin and that result from work exposure to chemicals, plants, or other substances.

-	Examples: Contact dermatitis, eczema, or rash caused by primary irritants and sensitizers or poisonous plants; oil acne, friction blisters, chrome ulcers, inflammation of the skin.

•	Respiratory Conditions:

-	Include illnesses associated with breathing hazardous biological agents, chemicals, dust, gases, vapors, or fumes at work.

-	Examples: Silicosis, asbestosis, pneumonitis, pharyngitis, rhinitis or acute congestion; farmer's lung, beryllium disease, tuberculosis, occupational asthma, reactive airways dysfunction syndrome (RADS), chronic obstructive pulmonary disease (COPD), hypersensitivity pneumonitis, toxic inhalation injury, such as metal fume fever, chronic obstructive bronchitis, and other pneumoconioses.

•	Poisoning:

-	Include disorders caused by the ingestion or absorption of toxic substances into the body leading to abnormal concentrations of toxic substances in blood, tissues, bodily fluids, or the breath.

-	Examples: Poisoning by lead, mercury, cadmium, arsenic, or other metals; poisoning by carbon monoxide, hydrogen sulfide, or other gases; poisoning by benzene, benzol, carbon tetrachloride, or other organic solvents; poisoning by insecticide sprays, such as parathion or lead arsenate; poisoning by other chemicals, such as formaldehyde.

•	All Other Illnesses:

-	Include all illnesses other than those in the preceding three categories.

-	Examples: Heatstroke, sunstroke, heat exhaustion, heat stress and other effects of environmental heat; freezing, frostbite, and other effects of exposure to low temperatures; decompression sickness; effects of ionizing radiation (isotopes, x-rays, radium); effects of nonionizing radiation (welding flash, ultra-violet rays, lasers); anthrax; bloodborne diseases, such as AIDS, HIV, hepatitis B, or hepatitis C; brucellosis; malignant or benign tumors; histoplasmosis; coccidioidomycosis.

(Note: OSHA is studying the general issue of ergonomics and musculoskeletal disorders (MSDs). On or after January 1, 2003, the agency may designate a separate illness column for MSDs and further specify the appropriate recording criteria. However, OSHA has provided very little guidance regarding the recordability of MSDs in calendar year 2002. The agency has simply stated (1) that MSDs are to be recorded if they satisfy the general three-part test (see Determining Recordable Cases in the New Federal 300 and 301 Logs) and (2) that "the employer is to check the column for 'injury' or 'all other illnesses,' depending on the circumstances of the case.")


Completing and Posting Form 300A

Under the revised recordkeeping rule, OSHA has created a separate form that summarizes the information in the OSHA 300 Log. This is known as the OSHA Form 300A. It is used for posting the employer's annual injury and illness history. A copy of Form 300A and the optional worksheet is included in Form 300A.

All employers are required to first review the OSHA 300 Log to make sure that the Form 300A is completed accurately. Beginning in calendar year 2003, the 300A Summary only--not the 300 Log--must be posted by February 1 of the year following the year covered by the form and must be kept posted until April 30 of that year.

If no injuries or illnesses have occurred in the year, the employer must still fill out and post the Form 300A. (Zeros, of course, will appear on the totals line.)

A company executive must certify that the Form 300A is accurate "based on his or her knowledge of the process in which the information was recorded." A "company executive" includes any of the following:

•	an owner of a company that is a sole proprietorship or partnership;

•	an officer of a corporation; or

•	the highest ranking company official at the establishment or his or her immediate supervisor.

The information for the Form 300A comes from data entered on the 300 Log. Typically, the information on the 300 Log is entered by non-executive employees. Before signing a certification, the executive should request that any lower-level employees who fill out the 300 Log or other logs verify the accuracy of the entries. In addition, the executive should make sure that all employees who enter information on the OSHA logs are well-trained regarding the agency's revised recordkeeping requirements.


Completing the 301 Log

The OSHA 301 Log supplements the information on the 300 Log. As with the 300 Log, employers must enter a recordable case on the 301 Log within seven days of notice of the injury or illness. Employers should note that they must also follow certain privacy rules for the 301 Log (see Entering Recordable Cases in the 300 Log).

A copy of the 301 Log may be found in Form 301. State workers' compensation, insurance, or other reports may be substituted for the OSHA 301 Log, as long as they provide the same information as the official federal form.

The 301 Log replaces the 101 Log. A number of topics in the 101 Log have been deleted because they duplicate the information already in the 300 Log, while several new sections have been added to provide additional helpful information in the 301 Log.

•	Items Deleted from 101 Log:

-	employer name and address

-	employee Social Security number, occupation, and department

-	place of accident (including whether it was on employer's premises)

-	name and address of hospital

•	Items Added to 301 Log:

-	date of employee's hiring

-	time the employee began work

-	time that the event occurred

-	whether the employee was treated at an emergency room

-	whether the employee was hospitalized overnight as an inpatient


Form 300

Information on completing this form is found in Determining Recordable Cases in the New Federal 300 and 301 Logs and Entering Recordable Cases in the 300 Log.

Form 300 Description

Form name	Log of Work-Related Injuries and Illnesses

Purpose	To record basic information about job-related accidents or illnesses for a calendar year

Description	This form records information such as the following:

•	name (except in privacy cases), occupation, and department of injured or ill employee

•	description of injury or illness

•	days away from work or restricted work for each injury

Alternatives	Other formats are permitted, as long as all information required on the OSHA 300 Log is noted on the alternative form.

Instructions	Follow instructions in this chapter or use those that accompany the form itself.

Posting	This log itself does not have to be posted. But the log provides the information used to complete the Form 300A, which must be posted.

Retention	Five years from the end of the year for which the form contains information

Enforcement	OSHA or state agency authorized to act on behalf of OSHA

The button below represents the OSHA Form 300 that is available in the OSHA Compliance Guide. To view a copy of the form, simply click on the button to open your Acrobat Reader® and select .pdf document. When you have finished viewing the form, close Acrobat Reader® or minimize it for later use in this guide.


Form 300A

Information on completing this form is found in Completing and Posting Form 300A.

Form 300A Description

Form name	Summary of Work-Related Occupational Injuries and Illnesses

Purpose	To summarize information about job-related accidents or illnesses for a calendar year

Description	This form records information such as the following:

•	total cases of employees with lost workdays

•	total cases with job transfer or restriction

•	total lost workdays for employees

•	total restricted workdays for employees

Alternatives	Other formats are permitted, as long as all information required on the OSHA 300A Log is noted on the alternative form.

Instructions	Follow instructions on the form itself and optional worksheet, as well as information in this chapter.

Posting	The Form 300A Summary must be posted--not the 300 Log itself. Post the 300A by February 1 of the year following the year covered and keep it posted until April 30 of that year.

Retention	Five years from the end of the year for which the form contains information

Enforcement	OSHA or state agency authorized to act on behalf of OSHA

The buttons below represent the OSHA Form 300A and accompanying worksheet that are available in the OSHA Compliance Guide. To view a copy of the form or worksheet, simply click on one of the buttons to open your Acrobat Reader® and select .pdf document. When you have finished viewing the form or worksheet, close Acrobat Reader® or minimize it for later use in this guide.


Form 301

Information on completing this form is found in Determining Recordable Cases in the New Federal 300 and 301 Logs and Completing the 301 Log.

Form 301 Description

Form name	Injury and Illness Incident Report

Purpose	To record additional information about each job-related injury or illness that must be recorded on the 300 Log

Description	This form records information such as:

•	time the employee began work

•	date of employee's hiring

•	time that the event occurred

•	whether the employee was treated at an emergency room or hospitalized overnight

Alternatives	Other formats are permitted (e.g., some workers' compensation carrier forms), as long as all information required on Form 301 is on the alternative form.

Instructions	Follow instructions on the form itself, as well as information in this chapter.

Posting	This form (or its alternative) does not need to be posted; however, it must be on file for review by OSHA officials if requested.

Retention	Five years from the year the injury or illness occurred

Enforcement	OSHA or state agency authorized to act on behalf of OSHA

The button below represents the OSHA Form 301 that is available in the OSHA Compliance Guide. To view a copy of the form, simply click on the button to open your Acrobat Reader® and select .pdf document. When you have finished viewing the form, close Acrobat Reader® or minimize it for later use in this guide.


Partially Exempt Businesses

This section provides a chart of business establishments that are partially exempt from OSHA recordkeeping requirements (see Overview of Recordkeeping Requirements). Under the revised rule, many current SIC exemptions have been repealed, and many new exemptions have been added.

SIC Code	Industry Description

525	Hardware Stores

542	Meat and Fish Markets

544	Candy, Nut, and Confectionery Stores

545	Dairy Products Stores

546	Retail Bakeries

549	Miscellaneous Food Stores

551	New and Used Car Dealers

552	Used Car Dealers

554	Gasoline Service Stations

557	Motorcycle Dealers

56	Apparel and Accessory Stores

573	Radio, Television and Computer Stores

58	Eating and Drinking Places

591	Drug Stores and Proprietary Stores

592	Liquor Stores

594	Miscellaneous Shopping Goods Stores

599	Retail Stores, Not Elsewhere Classified

60	Depository Institutions (banks and savings institutions)

61	Nondepository Institutions (credit institutions)

62	Security and Commodity Brokers

63	Insurance Carriers

64	Insurance Agents, Brokers, and Services

653	Real Estate Agents and Managers

654	Title Abstract Offices

67	Holding and Other Investment Offices

722	Photographic Studios, Portrait

723	Beauty Shops

724	Barber Shops

725	Shoe Repair and Shoeshine Parlors

726	Funeral Service and Crematories

729	Miscellaneous Personal Services

731	Advertising Services

732	Credit Reporting and Collection Services

733	Mailing, Reproduction, and Stenographic Services

737	Computer and Data Processing Services

738	Miscellaneous Business Service

764	Reupholstery and Furniture Repair

78	Motion Picture

791	Dance Studios, Schools, and Halls

792	Producers, Orchestras, Entertainers

793	Bowling Centers

801	Offices and Clinics of Medical Doctors

802	Offices and Clinics of Dentists

803	Offices of Osteopathic Physicians

804	Offices of Other Health Practitioners

807	Medical and Dental Laboratories

809	Health and Allied Services, Not Elsewhere Classified

81	Legal Services

82	Educational Services (schools, colleges, universities and libraries)

832	Individual and Family Services

835	Child Day Care Services

839	Social Services, Not Elsewhere Classified

841	Museums and Art Galleries

86	Membership Organizations

87	Engineering, Accounting, Research, Management, and Related Services

899	Services, Not Elsewhere Classified

Partially exempt businesses still must comply with accident reporting and posting requirements (see Accident Reporting Requirements and Posting Requirements). In addition, states with OSHA-approved plans may restrict or eliminate these SIC code exemptions (see State OSHA Plans).


Posting Requirements

All employers must display an OSHA poster that explains employee rights under OSHA regulations. This poster must be displayed even if the employer is exempt from OSHA recordkeeping requirements (see Overview of Recordkeeping Requirements).

OSHA has issued a new "plain language" poster (Publication 3165) to replace the existing poster (Publication 2203). OSHA intends to phase in use of the new poster as supplies of the existing poster diminish. Employers with an existing poster (Publication 2203) do not have to replace the poster with the more current Publication 3165 to comply with OSHA regulations.

The poster must be displayed in a prominent place in each factory, plant, establishment, construction site, or other area, workplace, or environment where work is performed. Reproductions or facsimiles of the poster must be at least 8 ½ by 14 inches with at least 10-point type. See For Additional Information for information on obtaining posters.

29 CFR 1903.2

OSHA Form 300A

Beginning in 2003, nonexempt employers must post Form 300A (see Completing and Posting Form 300A).

Miscellaneous Postings

Employers must also comply with the following additional posting rules:

•	Abatement Efforts: Notify employees by posting a copy of each document submitted to OSHA or a summary (place at or near the place of violation).

•	Variance Petition Summaries: Post summaries of any petitions for variances from OSHA standards or recordkeeping regulations.

•	OSHA Citations: Post either for three working days or until the hazard is corrected (whichever is longer) at or near each place of the alleged violation.

An employer that contests a citation still must post it, though the employer may also post notice of the contest. An employer filing a contest must post the following additional materials if affected employees are not represented by a union:

•	a notice of contest;

•	a notice that affected employees can participate in the hearings; and

•	a notice informing affected employees that all pleadings are available to inspect and copy at reasonable times.

29 CFR 1903.2; 1903.16; 1903.19


For Additional Information

For additional information on how to complete the new OSHA 300 and 301 Logs, as well as Form 300A, employers may download a copy of An Overview: Recording Work-Related Injuries and Illnesses, as well as related forms, from OSHA's Internet site. Copies of the OSHA poster are also available from the Internet site.

In addition, employers can contact an OSHA regional office to learn more about recordkeeping requirements or to obtain copies of the OSHA poster (see OSHA Regional and Area Offices).


Table of Contents

Safety Inspection Checklists

Introduction

Checklist Cover Sheet

Abrasive Wheel Equipment - Grinders

Aisles and Walkways

Bloodborne Pathogens

Building Exterior

Compressed Air Receivers

Compressed Gas Cylinders

Compressors and Compressed Air

Confined Space and Entry - General Requirements

Confined Space and Entry - Rescue Teams

Cranes

Dip Tanks

Electrical Equipment or Lines

Elevated Surfaces

Elevators

Emergency Action Plan

Employee Training

Employee Work Practices

Environmental Controls

Ergonomics

Exiting or Egress

Fire Protection

Flammable and Combustible Materials

Floor and Wall Openings

Floors

Forklifts

Forklift Training

Fueling

General Work Environment

Hand Tools and Equipment

Hazard Communication (Employee Right-to-Know)

Hazardous Chemicals Exposure

Hoist and Auxiliary Equipment

In-Plant Materials Handling

Lighting

Lock-Out, Tag-Out, and Block-Out Procedures

Machine Guarding

Machine Tools

Mail Handling

Materials Handling

Medical Services and First Aid

Noise

Offices

Personal Protective Equipment

Piping Systems

Portable Ladders

Portable (Power-Operated) Tools and Power Equipment

Posting

Potentially Hazardous Chemicals

Powder-Actuated Tools

Power Systems - Electrical

Power Systems - Hydraulic

Power Systems - Mechanical

Recordkeeping

Safety and Health Plan

Safety Committees

Sanitizing Equipment and Clothing

Scaffolds or Platforms

Spraying Operations

Stairs

Tire Inflation

Transporting Employees and Materials

Ventilation for Indoor Air Quality

Ventilation for Work Areas

Ventilation of Harmful Substances

Video Display Terminals (VDTs)

Waste Disposal

Welding, Cutting, and Brazing

Yard and Roads


Introduction

Safety Inspection Checklists

The following checklists may help employers to inspect their operations for compliance with the OSHA safety standards that are most frequently violated by employers. An employer may create its own set of checklists incorporating only those topics that apply to that employer.

The topics included in these checklists are also discussed in the Digest in Chapter 6. The Digest discussions include citations to the Code of Federal Regulations for use in researching the more detailed information contained in OSHA regulations. In the event of a legal question involving an OSHA standard (such as the appeal of an OSHA fine), an employer should refer to the regulation as published by OSHA.

These checklists involve summaries of information found in the official OSHA regulations. They may provide efficient assistance for employers in implementing the most frequently violated OSHA safety standards in the workplace. An employer should be able to answer "yes" to each question on all of the checklists. A "no" answer indicates potential safety problems.


Checklist Cover Sheet

SAFETY INSPECTION CHECKLIST

__________________________________________________________

company name

__________________________________________________________

street address

___________________________      __________________      _________________

city	state	ZIP code

Prepared by:

__________________________________________________________

print name of preparer

_________________________    ___________       __________________________

title	phone number

___________________________________  __       __________________________

signature	date


Abrasive Wheel Equipment - Grinders

	YES	NO
Is the work rest used and kept adjusted to within 1/8 inch of the wheel?
Is the adjustable tongue on the top side of the grinder used and kept adjusted to within 1/4 inch of the wheel?
Do side guards cover the spindle, nut, flange, and 75% of the wheel diameter?
Are bench and pedestal grinders permanently mounted?
Are goggles or face-shields always worn when grinding?
Is the maximum RPM rating of each abrasive wheel compatible with the RPM rating of the grinder motor?
Are fixed or permanently mounted grinders connected to their electrical supply system with metallic conduit or other permanent wiring method?
Does each grinder have an individual on/off control switch?
Is each electrically operated grinder effectively grounded?
Before new abrasive wheels are mounted, are they visually inspected and ring tested?
Are dust collectors and powered exhausts provided on grinders used in operations that produce large amounts of dust?
Are splash guards mounted on grinders that use coolant to prevent the coolant reaching employees?
Is cleanliness maintained around grinders?
_________________________________	________________

Inspector	Date


Aisles and Walkways

	YES	NO
Are aisles and passageways kept clear?
Are aisles and walkways appropriately marked?
Are wet surfaces covered with nonslip materials?
Are holes in the floor, sidewalk, or other walking surfaces covered, repaired properly, or otherwise made safe?
Is there safe clearance for walking in aisles when motorized or mechanical handling equipment is operating?
Are materials or equipment stored in such a way that sharp projections will not interfere with the walkway?
Are spilled materials cleaned up immediately?
Are changes of direction or elevation readily identifiable?
Are aisles or walkways that pass near moving or operating machinery, welding operations, or similar operation arranged so employees will not be subjected to potential hazards?
Is adequate headroom provided for the entire length of each aisle or walkway?
Are standard guardrails provided wherever aisle or walkway surfaces are elevated more than 30 inches above any adjacent floor or the ground?
Are bridges provided over conveyors and similar hazards?
_________________________________	________________

Inspector	Date


Bloodborne Pathogens

	YES	NO
Have potential occupational exposures to infectious agents in blood or other bodily fluids been identified?
Has a training and information program been provided for all employees with potential exposure to bloodborne pathogens?
Are employees informed that bloodborne pathogens are not limited to HIV and HBV, but include HCV, the spirochete that causes syphilis, and other disease-causing organisms?
Have appropriate controls been instituted (such as universal precautions, workplace practices, and personal protective equipment)?
Are sharps containers placed at a height to allow visibility (or purchased with transparent windows) to avoid overfilling?
Have employees been instructed in appropriate workplace practices (such as hand washing, handling of sharp instruments and laundry, and disposal of contaminated materials)?
Is the exposure control plan (ECP) reviewed annually to update and document technological changes that reduce or eliminate bloodborne pathogens exposure?
Is a log kept of percutaneous injuries involving contaminated sharps, including:
- the type and brand of device;
- the department and area involved; and
- an explanation of how the incident occurred?
Is input sought on engineering and work practice controls from non-managerial employees who:
- are responsible for patient care; and
- have occupational exposure to injuries from contaminated sharps?
Is personal protective equipment (PPE) used to protect employees only if the hazard cannot first be eliminated through the use of engineering controls or work practices?
When engineering controls and work practices cannot successfully control a hazard, is PPE provided to employees in all necessary locations?
Is equipment (mouthpieces, resuscitation bags, etc.) available for mouth-to-mouth resuscitation on potentially infected patients?
Are facilities/equipment available to implement appropriate workplace practices (such as sinks for washing hands, biohazard tags and labels, sharps containers, and detergents/disinfectants to clean up spills)?
Are all equipment and working surfaces cleaned and disinfected after contact with blood or other potentially infectious materials (OPIM)?
Is infectious waste properly labeled and placed in closable, leakproof containers, bags, or puncture-resistant holders?
Has HBV evaluation, antibody testing, and vaccination been made available to all potentially exposed employees?
Is the full hepatitis B vaccination series made available as soon as possible (no later than 24 hours) to all unvaccinated first aid providers who have rendered assistance in a situation involving blood or OPIM?
Is training performed at least annually in each of the following:
- universal precautions?
- personal protective equipment?
- appropriate workplace practices (including blood drawing, room cleaning, laundry handling, and cleanup of blood spills)?
- needlestick exposure/management?
- hepatitis B vaccination?
_________________________________	________________

Inspector	Date


Building Exterior

	YES	NO
Have any defective overhanging cornices, gutters, or tiling been repaired?
Have loose bricks on chimneys or stacks been corrected?
_________________________________	________________

Inspector	Date


Compressed Air Receivers

	YES	NO
Is every receiver equipped with a pressure gauge and with one or more automatic, spring-loaded safety valves?
Is the total relieving capacity of the safety valve capable of preventing pressure in the receiver from exceeding 10% over the maximum allowable working pressure of the receiver?
Is every air receiver provided with a drain pipe and valve at the lowest point for the removal of accumulated oil and water?
Are compressed air receivers periodically drained of moisture and oil?
Are all safety valves tested frequently and at regular intervals to determine whether they are in good operating condition?
If a high-pressure air system is being used, has it been inspected and approved?
Is the inlet of air receivers and piping systems kept free of accumulated oil and carbonaceous materials?
_________________________________	________________

Inspector	Date


Compressed Gas Cylinders

	YES	NO
Are cylinders with water weight capacity of over 30 pounds equipped with the means for connecting a valve protector device, or with a collar or recess to protect the valve?
Are cylinders legibly marked to clearly identify the gas contained?
Are compressed gas cylinders stored in areas that are protected from external heat sources such as intense radiant heat, flame, electric arcs, or high temperature lines?
Are cylinders located or stored in areas where they will not be damaged by passing or falling objects or subject to tampering by unauthorized persons?
Are cylinders stored or transported in a manner that prevents them from creating a hazard by tipping, falling, or rolling?
Are cylinders that contain liquefied fuel-gas stored or transported in a position so that the safety relief device is always in direct contact with the vapor space in the cylinder?
Are valve protectors always placed on cylinders when the cylinders are not in use or connected for use?
Are all valves closed off before a cylinder is moved, including when the cylinder is empty and at the completion of each job?
Are low pressure fuel-gas cylinders checked periodically for corrosion, general distortion, cracks, or any other defect that might indicate a weakness or render them unfit for service?
_________________________________	________________

Inspector	Date


Compressors and Compressed Air

	YES	NO
Are compressors equipped with pressure relief valves and pressure gauges?
Are compressor air intakes installed and equipped so that only clean, uncontaminated air enters the compressor?
Are air filters installed in the compressor intake?
Are safety devices on compressed air systems checked frequently?
Before any repair work is done on the pressure system of a compressor, is the pressure bled off and the system locked out?
Are signs posted to warn of the automatic starting feature of the compressors?
Is the belt drive system totally enclosed to provide protection for the front, back, top, and sides of the air compressor?
Is directing compressed air towards a person strictly prohibited?
Are employees prohibited from using highly compressed air for cleaning purposes?
If compressed air is used for cleaning off clothing, is the pressure reduced to less than 30 psi?
When using compressed air for cleaning, do employees wear protective chip guarding and personal protective equipment?
Are safety chains or other suitable locking devices used at the coupling of high pressure hose lines where a connection failure would create a hazard?
Before compressed air is used to empty containers of liquid, is the working pressure of the container checked to verify that it is safe?
When compressed air is used with abrasive blast cleaning equipment, is the operating valve a type that must be held open manually?
When compressed air is used to inflate auto tires, is a clip-on chuck and an in-line regulator preset to limit outgoing pressure to 40 psi?
Is using compressed air to clean up or move combustible dust prohibited if such action could cause the dust to be suspended in the air and cause a fire or explosion hazard?
_________________________________	________________

Inspector	Date


Confined Space and Entry - General Requirements

	YES	NO
Have all confined spaces been identified?
Are all employees who must work in confined spaces trained?
Is annual retraining provided for those working in confined spaces?
Is the confined space purged with fresh air?
Are lifelines, harness apparatus, and respirators in place?
Are confined spaces thoroughly emptied of any corrosive or hazardous substances, such as acids or caustics, before entry?
If the confined space contains inert, toxic, flammable, or corrosive materials, are all valves on lines off and blanked or disconnected and separated before entry?
Must all impellers, agitators, or other moving equipment inside confined spaces be locked out if they present a hazard?
Is either natural or mechanical ventilation provided to the confined space before entry?
Before entry, are appropriate atmospheric tests performed to check for oxygen deficiency, toxic substances, and explosive concentrations in the confined space?
Is adequate illumination provided for the work to be performed in the confined space?
Is the atmosphere inside the confined space frequently tested or continuously monitored during conduct of work?
Is there an assigned standby employee outside the confined space, when required, whose sole responsibility is to ensure safety by watching the work in progress, sounding an alarm if necessary, and rendering assistance?
Is the standby employee appropriately trained and equipped to handle an emergency?
Are the standby employee and other employees prohibited from entering the confined space without lifelines and respiratory equipment if there is any question as to the cause of the emergency?
Is approved respiratory equipment required if the atmosphere inside the confined space cannot be made acceptable?
Is all portable electrical equipment that is used inside confined spaces either grounded and insulated, or equipped with ground fault protection?
Before gas welding or burning is started in a confined space, are hoses checked for leaks, compressed gas bottles removed, torches lighted only outside the confined area, and is the confined area tested for explosive atmosphere, each time before a lighted torch is to be taken into the confined space?
If employees will be using oxygen-consuming equipment such as salamanders, torches, furnaces, etc., in a confined space, is sufficient air provided to ensure combustion without reducing the oxygen concentration of the atmosphere below 19.5% by volume?
Whenever combustion-type equipment is used in a confined space, are provisions made to ensure that the exhaust gases are vented outside the enclosure?
Is each confined space checked for decaying vegetation or animal matter that may produce methane?
Is the confined space checked for possible industrial waste that could contain toxic properties?
If the confined space is below ground and/or near areas where motor vehicles will be operating, is it possible for vehicle exhaust or carbon monoxide to enter the space?
_________________________________	________________

Inspector	Date


Confined Space and Entry - Rescue Teams

	YES	NO
Has the employer selected either an on-site or off-site rescue team in the event of an emergency involving a permit-required confined space?
Has the employer performed an initial evaluation to determine whether it is best to have an on-site or off-site team, and a performance evaluation to evaluate the team's effectiveness in an actual or practice rescue?
If an employer has selected an off-site rescue team for potential emergencies involving a permit-confined space:
- Has the off-site rescue service been evaluated to determine if its members are adequately equipped and trained?
- Can the off-site rescue service respond in a "timely manner"? (Note: This will vary depending on the circumstances and potential hazards of the confined space. For example, entry into immediately dangerous to life or health [IDLH] or potential IDLH atmospheres would require the rescue team to be standing at the permit space. For mere mechanical hazards [e.g., broken bones, abrasions], a 10- to 15-minute response time might be adequate.)
- Can the off-site rescue team quickly arrive at the permit space without traffic jams or other problems preventing a timely rescue?
- Does a communication method for the off-site rescue team exist so that any rescue request will be promptly transmitted to the rescue service?
- Does the rescue service have an ample supply of air-supplying SCBA respirators, including replacement cylinders (for rescues that may require more than a relatively short time)?
- Does the rescue service have the necessary technical knowledge and equipment to provide rope service or elevated rescue as needed?
- Does the rescue service have the necessary skills in medical evaluation, patient assistance, and emergency response?
- Does the rescue service have the necessary equipment to perform a rescue, and if not, is the equipment provided by the employer?
If the employer has designated its employees to provide permit-required space rescue and emergency services, has the employer taken all of the following measures:
- equipped employees with necessary personal protective equipment to conduct permit-required space rescues;
- trained affected employees in basic first aid and CPR;
- trained employees so that they are proficient in the proper use of personal protective equipment;
- trained affected employees to perform assigned rescue duties; and
- insured that affected employees practice permit-required space rescues at least once every 12 months in which they remove dummies, mannequins, or actual persons?
_________________________________	________________

Inspector	Date


Cranes

	YES	NO
Are cranes visually inspected for defects before each work shift?
Has a crane preventive maintenance program been established?
Are all electrically operated cranes effectively grounded?
Are all operators:
- provided with the manual for the crane being operated?
- trained for the particular crane being operated?
- in receipt of a valid operator's card?
Are operating controls clearly identified?
Is the load chart clearly visible to the operator?
Is a fire extinguisher provided at the operator's station?
Is the rated capacity visibly marked on each crane?
Is an audible warning device mounted on each crane?
Does the crane operator have enough lighting to perform the work safely?
Are boom stops used for cranes with booms that could fall over backwards?
Does each crane have a certificate to indicate that required testing and examinations have been performed?
Are crane inspection and maintenance records kept for review and inspection?
_________________________________	________________

Inspector	Date


Dip Tanks

	YES	NO
Are dip tanks strong enough to withstand any expected load?
Are dip tanks made of noncombustible materials whenever flammable or combustible materials are used?
When mechanical ventilation is used, does it:
- draw the flow of air into a hood or exhaust duct?
- provide an independent system for each dip tank (unless there is no possibility of fire, explosion, or chemical reaction)?
- provide a volume of outside air that is at least 90% of the volume of the exhaust air for each room having exhaust hoods?
Is a locker or storage space provided to employees to prevent contamination of their street clothes from liquids that may burn or harm the skin?
Is an emergency shower and eye-wash station (or complying water hose) close to the dipping or coating operation?
Is there at least one basin with a hot-water faucet for every 10 employees who work with dipping and coating liquids?
Is a physician's approval obtained before any employee with a sore, burn, or other skin lesion works in a vapor area?
Are vapor areas kept entirely free of combustible debris and as clear of combustible stock as possible?
If flammable or combustible liquids are involved, is there a properly trapped overflow pipe for any dip tank with a capacity over 150 gallons or with a liquid surface area greater than 10 feet?
Is there an automatic fire-extinguishing system for any dip tank with a capacity of at least 150 gallons or with a liquid surface area of at least four square feet?
Are hoods and duct work to the ventilation system inspected for corrosion or damage:
- at least quarterly during operation; and
- before operation after a prolonged shutdown?
Is the ventilation inspected to ensure adequate airflow:
- at least quarterly during operation; and
- before operation after a prolonged shutdown?
_________________________________	________________

Inspector	Date


Electrical Equipment or Lines

	YES	NO
Is compliance with OSHA specified for all contract electrical work?
Are all employees required to report as soon as possible any obvious hazard to life or property observed in connection with electrical equipment or lines?
Are employees instructed to make preliminary inspections and/or appropriate tests to determine what conditions exist before starting work on electrical equipment or lines?
When electrical equipment or lines are serviced, maintained, or adjusted, are necessary switches placed in the off position, locked out, and tagged whenever possible?
Are portable electrical tools and equipment grounded or double insulated?
Are electrical appliances such as vacuum cleaners, polishers, vending machines, etc., grounded?
Do extension cords have a grounding conductor?
Are multiple plug adapters prohibited?
Are ground-fault circuit interrupters installed on each temporary 15- or 20-ampere, 120-volt AC circuit at locations where construction, demolition, modifications, alterations, or excavations are being performed?
Are all temporary circuits protected by suitable disconnecting switches or plug connectors at the junction with permanent wiring?
Are electrical installations placed away from hazardous dust or vapor areas?
If the "YES" box was checked for the last question, do the electrical installations meet with the requirements of the National Electrical Code (NEC) for hazardous locations?
Are exposed wires and cords with frayed or deteriorated insulation repaired or replaced promptly?
Are flexible cords and cables free of splices and taps?
Are clamps or other securing means provided on flexible cords or cables at plugs, receptacles, tools, equipment, etc., and is the cord jacket securely held in place?
Are all cord, cable, and raceway connections intact and secure?
In a wet or damp location, are electrical tools and equipment protected or appropriate for use in that location?
Is the location of electrical power lines and cables (overhead, underground, under floor, other side of walls, etc.) determined before digging or drilling or beginning similar work?
Are metal measuring tapes, ropes, hand lines, or similar devices with metallic thread woven into the fabric prohibited where they could come in contact with energized parts of equipment or circuit conductors?
Is the use of metal ladders prohibited in areas where the ladder or the person using the ladder could come in contact with energized parts of equipment, fixtures, or circuits?
Are all disconnecting switches and circuit breakers labeled to indicate their use or equipment served?
Are disconnecting means always opened before fuses are replaced?
Do all interior wiring systems include provisions for grounding metal parts of electrical raceways, equipment, and enclosures?
Are all electrical raceways and enclosures securely fastened in place?
Are all energized parts of electrical circuits and equipment guarded with approved cabinets or enclosures?
Is sufficient access and working space provided and maintained around all electrical equipment to permit ready and safe operations and maintenance?
Are all unused openings (including conduit knockouts) in electrical enclosures and fittings closed with appropriate covers, plugs, or plates?
Are electrical enclosures such as switches, junction boxes, etc., provided with tight-fitting covers or plates? (Switches must be horsepower rated equal to or in excess of the motor horsepower rating.)
For electrical motors in excess of two horsepower, are there disconnecting switches capable of opening the circuit when the motor is in a stalled condition?
Is low-voltage protection provided in the control device of any motor-driven machine that is likely to cause injury if inadvertently started?
Is each motor disconnecting switch or circuit breaker located within sight of the motor control device?
For each motor:
- is the motor located within sight of its controller; or
- is the controller capable of being locked in the open (disconnected) position; or
- is a separate disconnector installed in the circuit within sight of the motor?
Does the controller for each motor in excess of two horsepower have a rating that is at least equal to the horsepower rating of the motor it serves?
Are employees who regularly work on or around energized electrical equipment or lines instructed in cardiopulmonary resuscitation (CPR) methods?
Are employees prohibited from working alone on lines or equipment that are energized with over 600 volts?
_________________________________	________________

Inspector	Date


Elevated Surfaces

	YES	NO
Are signs posted, when appropriate, showing the elevated surface load capacity?
Are surfaces that are elevated more than 30 inches above the floor or ground provided with standard guardrails?
Are all elevated surfaces beneath which people or machinery could be exposed to falling objects provided with standard four-inch toeboards?
Is a permanent means of access and egress provided to elevated storage and work surfaces?
Is required headroom provided where necessary?
Is material on elevated surfaces piled, stacked, or racked in a manner to prevent it from tipping, falling, collapsing, rolling, or spreading?
Are dockboards or bridge plates used when transferring materials between docks and trucks or rail cars?
_________________________________	________________

Inspector	Date


Elevators

	YES	NO
Are motors properly protected from dirt and steam?
Is electrical wiring in good repair?
Are fire extinguishers available?
Is there protection for electrical control panels?
Are hoist-way interlocks operating and protected?
Is the satisfactory condition of the elevator marked?
Is the safe load capacity of the elevator marked?
Are emergency exits provided?
Are safety devices tested and working properly?
Is the elevator inspected? Most recent date: ___________
_________________________________	________________

Inspector	Date


Emergency Action Plan

	YES	NO
Has an Emergency Action Plan been developed and have emergency escape procedures and routes been designated?
Have emergency procedures and routes been communicated to all employees?
Do employees know their responsibilities:
- for reporting emergencies?
- for performing rescue and medical duties during an emergency?
Are employees who must remain behind temporarily to operate critical operations before evacuating familiar with proper procedures?
Is the employee alarm system for emergency action recognizable and perceptible above ambient conditions?
Are alarm systems properly maintained and tested regularly?
Is the Emergency Action Plan reviewed and revised periodically?
_________________________________	________________

Inspector	Date


Employee Training

	YES	NO
Do all new employees receive basic safety orientation?
Are new employees trained in the safe working practices of their jobs?
Are transferred employees trained in the safe working practices of their jobs?
Have all employees been trained on the hazardous chemicals used in the workplace?
_________________________________	________________

Inspector	Date


Employee Work Practices

	YES	NO
Is baggy clothing, flyaway hair, or dangling jewelry prohibited?
Are sturdy shoes required for the work environment?
Do employees avoid overexertion or excessive repetitive motions?
_________________________________	________________

Inspector	Date


Environmental Controls

	YES	NO
Are all work areas properly illuminated?
Are employees instructed in first aid and other emergency procedures?
Are hazardous substances identified that may cause harm by inhalation, ingestion, skin absorption, or eye contact?
Are employees aware of the hazards of the chemicals they may be exposed to in the work environment?
Is employee exposure to chemicals in the workplace kept within acceptable levels?
Are the safest methods or work procedures being used?
Is the work area's ventilation system appropriate for the work being performed?
Are spray-painting operations done in spray rooms or booths equipped with an appropriate exhaust system?
Is employee exposure to welding fumes controlled by ventilation, use of respirators, exposure time, or other means?
Are welders and other workers nearby provided with flash shields during welding operations?
If forklifts or other vehicles are used in buildings or other enclosed areas, are the carbon monoxide levels kept below the maximum acceptable concentration?
Has there been a determination that noise levels in the facilities are within acceptable levels?
Are steps being taken to use engineering controls to reduce excessive noise levels?
Are proper precautions being taken when handling asbestos and other fibrous materials?
Are wet methods used, when practicable, to prevent the emission of airborne asbestos fibers, silica dust, and similar hazardous materials?
Is vacuuming with appropriate equipment used whenever possible rather than blowing or sweeping dust?
Are grinders, saws, and other machines that produce dust vented to an industrial collector or central exhaust system?
Are all local exhaust ventilation systems designed and operating properly?
In particular:
- Do all local exhaust ventilation systems have the volume of air flow necessary for the application?
- Are ducts unplugged?
- Are belts not slipping?
Is personal protective equipment provided, used, and maintained wherever required?
Are there written standard operating procedures for the selection and use of respirators where needed?
Are restrooms and washrooms kept clean and sanitary?
Is all water provided for drinking, washing, and cooking potable?
Are all outlets for water that is not suitable for drinking clearly identified?
Are employees' physical capacities assessed before being assigned to jobs requiring heavy work? Are reasonable accommodations provided if requested by an employee?
Are employees instructed in the proper manner of lifting heavy objects?
Where heat is a problem, have all fixed work areas been provided with spot cooling or air conditioning?
Before assignment to areas of high heat, are employees asked if their health conditions might make them more susceptible to having an adverse reaction? If an employee answers "yes", are either reasonable accommodations or medical tests provided to verify the employee's answer?
Are employees who work on streets and roadways where they are exposed to the hazards of traffic required to wear brightly colored (traffic-orange) warning vests?
Are exhaust stacks and air intakes located so that contaminated air will not be recirculated within a building or other enclosed area?
_________________________________	________________

Inspector	Date


Ergonomics

	YES	NO
Are employees informed of the potential signs and symptoms of musculoskeletal disorders (MSDs), such as pain, numbness, or tingling in hands or feet?
Are employees informed of all of the following potential risk factors for MSDs:
- awkward postures;
- forceful exertions;
- repetitive motions;
- excessive task durations;
- contact stresses;
- vibration;
- machine-paced work; and
- extreme hot or cold temperature?
Can the employee perform the work:
- without eye strain or glare?
- without repetitive lifting of the arms above the shoulder level?
- without holding his or her elbows out and away from the body?
- without having to stoop at the shoulders to view the work?
Can the employee keep his or her hands and wrists in a neutral position while working?
Are body pressure points (wrists, forearms, backs of thighs) avoided during performance of the task?
Are sufficient rest breaks, in addition to regular rest breaks, provided to relieve stress from repetitive motion tasks?
Are tools, instruments, and machinery shaped and positioned for comfort and ease of use?
Is furniture positioned and adjusted to minimize strain on the body?
Are mechanical assists used whenever possible for materials-handling tasks, especially for workers pushing and pulling heavy objects?
Are unnecessary distances eliminated when moving materials?
Are lifts confined within the knuckle-to-shoulder zone?
Are tasks arranged to minimize the use of fixed positions and postures?
Are employees instructed not to lift and carry too much weight?
Are height-adjustable material bins considered for use in reducing the stress on employees?
Are automated devices considered for use in performing certain routine repetitive tasks (e.g., stapling, sorting, filing)?
Are employees encouraged to stretch their muscles and ligaments to "prep" them before beginning work?
Are employees given enough breaks to allow their muscles, tendons, and ligaments to recover from repetitive stresses?
_________________________________	________________

Inspector	Date


Exiting or Egress

	YES	NO
Are all exits marked with an exit sign and illuminated by a reliable light source?
Are the directions to exits, when not immediately apparent, marked with visible signs?
Are doors, passageways, or stairways that are neither exits nor accessible to exits, but that could be mistaken for exits, appropriately marked (for example: "NOT AN EXIT," "TO BASEMENT," "STOREROOM," etc.)?
Are exit signs provided with the word "EXIT" in lettering at least 6 inches high and the stroke of the lettering at least 1/2-inch wide?
Are exit doors side-hinged?
Are all exits kept free of obstructions?
Are at least two means of egress provided from elevated platforms, pits, or rooms where the absence of a second exit would increase the risk of injury from hot, poisonous, corrosive, suffocating, flammable, or explosive substances or other hazards?
Are there sufficient exits to permit prompt escape in case of an emergency?
Are special precautions taken to protect employees during construction and repair operations?
Is the number of exits from each floor of a building and the number of exits from the building itself appropriate for the building occupancy load?
Are exit stairways, which are required to be separated from other parts of a building, enclosed by at least two-hour, fire-resistant construction in buildings more than four stories in height, and not less than one-hour, fire-resistant construction elsewhere?
Where exiting will occur through flameproof glass doors, glass exit doors, storm doors, etc., are the doors fully tempered to meet the safety requirements for human impact?
_________________________________	________________

Inspector	Date


Fire Protection

	YES	NO
Is the local fire department well-acquainted with the facilities and their location and specific hazards?
If there is a fire alarm system, is it certified as required?
If there is a fire alarm system, is it tested at least annually?
If there are interior stand pipes and valves, are they inspected regularly?
If there are outside private fire hydrants, are they flushed at least once a year and on a routine preventive maintenance schedule?
Are fire doors and shutters unobstructed and protected against obstructions, including their counterweights?
Are fire door and shutter fusible links in place?
Are air and water pressure on automatic sprinkler system water control valves checked weekly or periodically as required?
Is the maintenance of automatic sprinkler systems assigned to responsible persons or to a sprinkler contractor?
Are sprinkler heads protected by metal guards when exposed to physical damage?
Is proper clearance maintained below sprinkler heads?
Are portable fire extinguishers provided in adequate number and type?
Are fire extinguishers mounted in accessible locations?
Are fire extinguisher locations properly marked?
Are fire extinguishers recharged regularly, and is the date of recharge noted on the inspection tag?
Are employees periodically instructed in the use of extinguishers and fire protection?
_________________________________	________________

Inspector	Date


Flammable and Combustible Materials

	YES	NO
Are combustible scraps, debris, and waste materials (oily rags, etc.) stored in covered metal receptacles and removed from the worksite promptly?
Is proper storage practiced to minimize the risk of fire, including spontaneous combustion?
Are approved containers and tanks used for the storage and handling of flammable and combustible liquids?
Are safety cans used for dispensing flammable or combustible liquids at the point of use?
Are all connections on drums and combustible liquid piping tight for both vapors and liquid?
Are all flammable liquids kept in closed containers when not in use (for example, parts cleaning tanks, pans, etc.)?
Are bulk drums of flammable liquids grounded and bonded to containers during dispensing?
Do storage rooms for flammable and combustible liquids have explosion-proof lights?
Do storage rooms for flammable and combustible liquids have mechanical or gravity ventilation?
Is liquefied petroleum gas stored, handled, and used in accordance with safe practices and standards?
Are "NO SMOKING" signs posted on gas tanks?
Are liquefied petroleum storage tanks guarded to prevent damage from vehicles?
Are all solvent wastes and flammable liquids kept in fire-resistant, covered containers until removed from the worksite?
Is vacuuming used whenever possible rather than blowing or sweeping combustible dust?
Are firm separators placed between containers of combustibles or flammables, when stacked one on another, to assure their support and stability?
Are fuel-gas cylinders and oxygen cylinders separated by distance, fire resistant barriers, etc., while in storage?
Are appropriate fire extinguishers used for the following classes of materials:
Class A Ordinary combustible material fires?
Class B Flammable liquid, gas, or grease fires?
Class C Energized-electrical equipment fires?
Are appropriate fire extinguishers mounted within 75 feet of outside areas containing flammable liquids and within 10 feet of any inside storage area for such materials?
Are extinguishers free from obstructions or blockage?
Are all extinguishers serviced and tagged at least yearly?
Are extinguishers fully charged and in designated places?
Where sprinkler systems are permanently installed, are the nozzle heads directed so that water will not be sprayed into operating electrical switch boards and equipment?
Are "NO SMOKING" signs posted and enforced in areas where flammable or combustible material is used or stored?
Are flammable or combustible spills cleaned up promptly?
Are storage tanks adequately vented to prevent the development of excessive vacuum or pressure as a result of filling, emptying, or atmospheric temperature changes?
Are storage tanks equipped with emergency venting that relieves excessive internal pressure caused by fire exposure?
_________________________________	________________

Inspector	Date


Floor and Wall Openings

	YES	NO
Are floor openings guarded by a cover, guardrail, or equivalent on all sides (except at entrances to stairways or ladders)?
Are toeboards installed around the edges of permanent floor openings (if people may pass below the opening)?
Are skylight screens of such construction and mounting that they will withstand a load of at least 200 pounds?
Is the glass in the windows, doors, glass walls, etc., that are subject to human impact of sufficient thickness and type for the condition of use?
Are grates or similar-type covers over floor openings, such as floor drains, of such design that foot traffic or rolling equipment will not be affected by the grate spacing?
Are unused portions of service pits and pits not actually in use either covered or protected by guardrails or equivalent?
Are manhole covers, trench covers, and similar covers, plus their supports, designed to carry a truck rear axle load of at least 20,000 pounds when located in roadways and subject to vehicle traffic?
Are doors or floor covers for floor or wall openings in fire-resistant construction compatible with the fire rating of the structure and provided with self-closing features, when appropriate?
_________________________________	________________

Inspector	Date


Floors

	YES	NO
Are slip, trip, or fall hazards corrected as soon as possible?
Are apertures or openings enclosed, not covered?
Are the floors clean, orderly, and free of oil or grease hazards?
Are there grates over floor drains?
Are there nonslip surfaces wherever possible?
_________________________________	________________

Inspector	Date


Forklifts

	YES	NO
Is there a checklist for the start of the shift?
Are load capacities labeled?
Are load backrest extensions in place?
Is the speed posted?
Are there slow-down ramps?
Are there forks placed evenly across the load?
Are riders prohibited?
Are railroad tracks crossed diagonally?
Are pedestrians given the right-of-way?
Are trailer truck or boxcar floors checked for safety of load?
Is the key removed from the truck when out of operation?
Are only employees who have been trained in the proper use of hoists allowed to operate them?
Are only trained personnel allowed to operate industrial trucks?
Are employees instructed that they must wear seat belts if provided by the manufacturer of the particular forklift?
Is substantial overhead protective equipment provided on high-lift rider equipment?
Are the required lift truck operating rules posted and enforced?
Is directional lighting provided on each industrial truck that operates in an area with less than two-foot candles per square foot of general lighting?
Does each industrial truck have a warning horn, whistle, gong, or other device that can be clearly heard above the normal noise in the areas where operated?
Are the brakes on each industrial truck capable of bringing the vehicle to a complete and safe stop when fully loaded?
Will each industrial truck's parking brake effectively prevent the vehicle from moving when unattended?
Are any industrial trucks that operate in areas where flammable gases or vapors, combustible dust or ignitable fibers may be present in the atmosphere approved for such locations?
Are motorized hand and hand/rider trucks designed so that the brakes are automatically applied and the power to the drive motor shuts off when the operator releases his or her grip on the device that controls the travel?
Are industrial trucks with internal combustion engines that operate in buildings or enclosed areas carefully checked to ensure that such operations do not cause harmful concentrations of dangerous gases or fumes?
_________________________________	________________

Inspector	Date


Forklift Training

	YES	NO
Does forklift training involve each of the following three elements:
- formal instruction (e.g., lectures, video tapes, interactive computer training, written materials)?
- practical training (i.e., demonstrations performed by the trainer and practical exercises performed by the trainee)?
- the trainee passing an actual driving evaluation before beginning his or her initial job assignment?
Are trainees given instructions and precautions regarding:
- differences from automobiles?
- the type of forklift they will drive?
- steering and maneuvering?
- location and operation of controls and instrumentation?
- operating limitations and necessary warnings?
Are trainees instructed regarding forklift capacity and stability?
Are trainees instructed to do all of the following whenever carrying a load that approaches a forklift's maximum design characteristics:
- carry the load at the lowest position possible?
- accelerate the truck slowly and evenly?
- tilt the forks forward cautiously?
Are trainees instructed on:
- engine operation and maintenance?
- vehicle inspection and maintenance?
- engine refueling and battery recharging?
Are trainees instructed on driving and visibility (including restrictions caused by loading)?
Are trainees instructed regarding the use and limits of forks and attachments?
Are trainees trained for the specific hazards posed by the particular forklift they will be operating?
Are trainees given additional training whenever they:
- operate a forklift that poses new or additional hazards?
- work in substantially different or changed conditions?
- are involved in any forklift accident, near-miss accident, or instance of unsafe operation?
Are trainees given refresher training at least every three years?
Are trainees instructed regarding all of the following topics:
- conditions of surfaces on which the forklift will be operated (rough, uneven, or sloped surfaces, greasy or slippery spots, etc.?
- composition of probable loads and ensuring of load stability?
- manipulation, stacking, and unstacking of loads?
- narrow aisles and other restricted places of operation?
- pedestrian traffic?
- operation in hazardous (classified) locations?
- operation on ramps or other sloped surfaces that could affect the vehicle's stability?
- operation in closed environments where poor ventilation can pose a danger of carbon monoxide buildup?
- any unique or potentially hazardous environments that exist or may exist in the workplace?
_________________________________	________________

Inspector	Date


Fueling

	YES	NO
Is fueling an internal combustion engine with a flammable liquid while the engine is running prohibited?
Are fueling operations done in such a manner that the likelihood of spillage will be minimal?
When spillage occurs during fueling operations, is the spilled fuel washed away completely or evaporated, or are other measures taken to control vapors before restarting the engine?
Are fuel tank caps replaced and secured before starting the engine?
In fueling operations, is there always metal contact between the container and the fuel tank?
Are fueling hoses of a type designed to handle the specific type of fuel?
Is handling or transferring gasoline in open containers prohibited?
Are open lights, open flames, or sparking or arcing equipment prohibited near fueling or transfer-of-fuel operations?
Is smoking prohibited in the vicinity of fueling operations?
Are fueling operators prohibited in buildings or other enclosed areas that are not specifically ventilated for this purpose?
Where fueling or transfer of fuel is done through a gravity flow system, are the nozzles of the self-closing type?
_________________________________	________________

Inspector	Date


General Work Environment

	YES	NO
Are all worksites clean and orderly?
Are work surfaces kept dry or are appropriate means taken to ensure that the surfaces are slip-resistant?
Are all spilled materials or liquids cleaned up immediately?
Are combustible scrap, debris, and waste stored safely and removed from the workplace promptly?
Are accumulations of combustible dust routinely removed from elevated surfaces, including the overhead structure of buildings, etc.?
Is combustible dust cleaned up with a vacuum system to prevent the dust from going into suspension?
Is metallic or conductive dust prevented from entering or accumulating on or around electrical enclosures or equipment?
Are covered metal waste cans used for oily and paint-soaked waste?
If so, are they properly labeled?
Are all oil- and gas-fired devices equipped with flame-failure controls that will prevent the flow of fuel if pilots or main burners are not working?
Are all spray-paint booths, dip tanks, etc., cleaned regularly?
Are the minimum number of toilets and washing facilities provided?
Are all toilets and washing facilities clean and sanitary?
Are all work areas adequately illuminated?
Are pits and floor openings covered or otherwise guarded?
Are all lights at least seven feet above the work area, unless protected?
_________________________________	________________

Inspector	Date


Hand Tools and Equipment

	YES	NO
Are all tools and equipment (both company- and employee-owned) used by employees in the workplace in good condition?
Are hand tools such as chisels, punches, etc., that develop mushroomed heads during use reconditioned or replaced as necessary?
Are broken or fractured handles on hammers, axes, and similar equipment replaced promptly?
Are worn or bent wrenches replaced regularly?
Are appropriate handles used on files and similar tools?
Are employees made aware of the hazards caused by faulty or improperly used hand tools?
Are appropriate safety glasses, face-shields, etc., worn while using hand tools or equipment that might produce flying materials or be subject to breakage?
Are jacks checked periodically to assure they are in good operating condition?
Are tool handles wedged tightly in the head of all tools?
Are tool cutting edges kept sharp so the tool will move smoothly without binding or skipping?
Are tools stored in a dry, secure location where they will not be tampered with?
Is eye and face protection worn when driving hardened or tempered studs or nails?
_________________________________	________________

Inspector	Date


Hazard Communication (Employee Right-to-Know)

	YES	NO
Has a list of all hazardous chemicals in the workplace been prepared?
Does the company have a method for updating the hazardous chemical list?
Has the company obtained or developed a Material Safety Data Sheet for each hazardous chemical used?
Has a system been developed to ensure that all incoming hazardous chemicals have labels and data sheets?
Are procedures in place to ensure labeling for containers of hazardous chemicals?
Are employees aware of the requirements of the Hazard Communication Standard and information specific to their workplace?
Are employees familiar with the hazards of the chemicals in their workplace?
Have employees been informed of the hazards associated with performing non-routine tasks?
Do employees understand how to detect the presence or release of hazardous chemicals in their workplace?
Are employees trained about proper work practices and personal protective equipment in relation to the hazardous chemicals in their work area?
Does the training program provide information on appropriate first aid, emergency procedures, and the likely symptoms of overexposure?
Does the training program include an explanation of labels and warnings that are used in each work area?
Does the training describe where employees obtain data sheets and how employees use them?
Is a system in place to ensure that new employees are trained before beginning work?
Is a system in place to identify new hazardous chemicals before they are introduced into a work area?
Is a system in place to inform employees of the hazards associated with newly introduced chemicals?
_________________________________	________________

Inspector	Date


Hazardous Chemicals Exposure

	YES	NO
Are employees trained in the safe handling practices of hazardous chemicals such as acids, caustics, etc.?
Are employees aware of the potential hazards involving various chemicals stored or used in the workplace such as acids, bases, caustics, epoxies, phenols, etc.?
Is employee exposure to chemicals kept within acceptable levels?
Are eye wash fountains and safety showers provided in areas where corrosive chemicals are handled?
Are all containers of hazardous chemicals, such as vats, storage tanks, etc., labeled (for example, "CAUSTICS")?
Are all employees required to use personal protective clothing and equipment when handling chemicals (e.g., gloves, eye protection, respirators, etc.)?
Are flammable or toxic chemicals kept in closed containers when not in use?
Are chemical piping systems clearly marked as to their content?
Where corrosive liquids are frequently handled in open containers or drawn from storage vessels or pipelines, are adequate means readily available for properly and safely neutralizing or disposing of spills and overflows?
Have standard operating procedures been established, and are they being followed when cleaning up chemical spills?
Where needed for emergency use, are respirators stored in a convenient, clean, and sanitary location?
Are the respirators adequate for the emergency uses for which they may be needed?
Are employees prohibited from eating in areas where hazardous chemicals are present?
Is personal protective equipment provided, used, and maintained whenever necessary?
Are there written standard operating procedures for the selection and use of respirators where needed?
If there is a Respiratory Protection Plan, are employees instructed on the correct use and limitations of the respirators?
Are the respirators NIOSH-approved for their particular application?
Are respirators regularly inspected and cleaned, sanitized, and maintained?
If hazardous substances are used in any processes, is there a medical or biological monitoring system in operation?
Is the employer familiar with the Threshold Limit Values or Permissible Exposure Limits of airborne contaminants and physical agents used in the workplace?
Have control procedures been instituted for hazardous materials where appropriate, such as respirators, ventilation systems, handling practices, etc.?
Whenever possible, are hazardous substances handled in properly designed and exhausted booths or similar locations?
Are general dilution or local exhaust ventilation systems used to control dusts, vapors, gases, smoke, solvents, or mists that may be generated in the workplace?
Is ventilation equipment provided and operating properly for the removal of contaminants from operations such as production grinding, buffing, spray painting, or vapor degreasing?
Have employees been surveyed about dizziness, headaches, nausea, irritation, or other complaints when they use solvents or other chemicals?
Have employees been surveyed about dryness, irritation, sensitization of the skin, or other dermatitis problems?
Has the use of an industrial hygienist or environmental health specialist to evaluate the operation been considered?
If internal combustion engines are used, is carbon monoxide kept within acceptable levels?
_________________________________	________________

Inspector	Date


Hoist and Auxiliary Equipment

	YES	NO
Is each overhead electric hoist equipped with a limit device to stop a hook at its highest and lowest safe points?
Will each hoist automatically stop and hold any load up to 125% of its rated load, if its actuating force is removed?
Is the rated load of each hoist legibly marked and visible to the operator?
Are stops provided at safe limits for trolley hoist travel?
Are the controls of the hoist plainly marked to indicate the direction of travel or motion?
Does each cage-controlled hoist have a warning device?
Are close-fitting guards or other suitable devices installed on hoists so that hoist ropes are maintained in the grooves?
Are all hoist chains or ropes of sufficient length to handle the full range of movement of the application while still maintaining two full wraps on the drum at all times?
Are guards provided for nip points or contact points between hoist ropes and permanent sheaves that are located within seven feet of the floor, ground, or working platform?
Are chains or rope slings that are kinked prohibited?
Is it prohibited to use the hoist rope or chain wrapped around the load as a substitute for a sling?
Is the operator instructed to avoid carrying loads over people?
_________________________________	________________

Inspector	Date


In-Plant Materials Handling

	YES	NO
Are dockboards available?
Are trailer-truck wheel chocks available in receiving/shipping areas?
Are pallets and skids in good repair?
Is there a special storage area for unused skids and pallets?
Is there a procedure to set aside broken skids and pallets?
Are paths, aisles, and stairways clear of obstructions?
Is there proper drainage to prevent the accumulation of water or solvents?
_________________________________	________________

Inspector	Date


Lighting

	YES	NO
Is the illumination level sufficient for work performed?
Is emergency lighting adequate and operating?
Is there emergency lighting for all exit routes?
_________________________________	________________

Inspector	Date


Lock-Out, Tag-Out, and Block-Out Procedures

	YES	NO
Is all machinery or equipment that is capable of movement required to be de-energized, disengaged and blocked, or locked-out during:
- cleaning;
- servicing; and
- adjusting or setting-up operations?
If disconnecting the power equipment does not also disconnect the electrical control circuit, are means provided to assure the control circuit can also be disconnected and locked out?
If disconnecting the equipment does not disconnect the electrical control circuit, is each source of power and all electrical enclosures identified properly?
Is the locking out of control circuits in lieu of locking out main power disconnects prohibited?
Are all equipment control valve handles provided with a means for locking out?
Does the lock-out procedure require that stored energy (mechanical, hydraulic air, etc.) be released or blocked before equipment is locked out for repairs?
Are appropriate employees provided with individually keyed personal safety locks?
Are employees required to keep personal control of their keys while they have safety locks in use?
Can only the employee who is exposed to the hazard place or remove the safety lock?
Are employees required to check the safety of the lock out by attempting a startup after making sure no one is exposed?
Are employees instructed always to push the control circuit stop button before re-energizing the main power switch?
Is there a means provided to identify employees who are working on locked-out equipment by their locks or accompanying tags?
Is a sufficient number of accident prevention signs or tags and safety padlocks provided for any reasonably foreseeable repair emergency?
When machine operation, configuration, or size requires the operator to leave his or her control station to install tools or perform other operations, and that part of the machine could move if accidentally activated, is that part of the machine required to be separately locked out or blocked out?
In the event that equipment or lines cannot be shut down, locked out, and tagged, is a safe job procedure established and rigidly followed?
_________________________________	________________

Inspector	Date


Machine Guarding

	YES	NO
Is there a training program to instruct employees on safe methods of machine operation?
Is there adequate supervision to ensure that employees are following safe machine operating procedures?
Is there a program for regular safety inspection of machinery and equipment?
Is all equipment kept clean and properly maintained?
Is sufficient clearance provided around and between machines to allow for safe operations, setup and servicing, materials handling, and waste removal?
Is equipment securely placed or anchored to prevent tipping or other movements that could result in personal injury?
Does each machine operator have a power shut-off switch within reach?
Can electric power to each machine be locked out for maintenance, repair, or security?
Are the non-current-carrying metal parts of electrically operated machines bonded and grounded?
Are foot-operated switches guarded or arranged to prevent accidental actuation by personnel or falling objects?
Are manually operated valves and switches controlling the operation of equipment and machines clearly identified and readily accessible?
Are all emergency stop buttons colored red?
Are all pulleys and belts that are within seven feet of the floor or working level properly guarded?
Are all moving chains and gears properly guarded?
Are splash guards mounted on machines that use coolant to prevent the coolant from reaching employees?
Are methods provided to protect the operator and other employees in the machine area from hazards created at the point of operation? Are nip points, rotating parts, flying chips, and sparks all in-going?
Are machinery guards secure and arranged so that they do not present a hazard in their use?
If special hand tools are used for placing and removing material, do they protect the operator's hands?
Are revolving drums, barrels, and containers required to be guarded by an enclosure that is interlocked with the drive mechanism, so that revolution cannot occur unless the guard enclosure is in place?
Do arbors and mandrels have firm and secure bearings, and are they free from play?
Are provisions made to prevent machines from automatically starting when power is restored after a power failure or shutdown?
Are machines free from excessive vibration when the largest-sized tool is mounted and run at full speed?
If machinery is cleaned with compressed air, is air pressure controlled and personal protective equipment or other safeguards used to protect operators and other workers from eye and body injury?
Are fan blades protected by a guard with openings no larger than 1/2 inch, if operating within seven feet of the floor?
Are saws that are used for ripping equipped with anti-kick devices and spreaders?
Are radial arm saws arranged so that the cutting head will gently return to the back of table when released?
_________________________________	________________

Inspector	Date


Machine Tools

	YES	NO
Is there guarding for the power transmission equipment?
Is there guarding for pinch points, in-running points, and points of operation?
Are interlock guards in operation?
Is eye protection available where needed?
Are operating controls locked when not in use?
Are emergency stop buttons readily accessible and operable?
Are guards or deflection equipment provided for chips or sparks from rotating equipment?
Are machine tool operators properly trained in operation of equipment?
_________________________________	________________

Inspector	Date


Mail Handling

	YES	NO
Are employees instructed:
- to be observant for suspicious envelopes or packages?
- to open all mail with a letter opener or method that is least likely to disturb its contents?
- not to use hands to open mail?
- to open packages/envelopes with a minimum amount of movement?
- not to blow into envelopes?
- not to shake, sniff, or pour out contents?
- to keep hands away from nose and mouth while opening mail?
- to wash hands after handling mail?
- to immediately notify management of any suspicious mail or package?
Have employees been trained that any of the following may be a sign of a suspicious package or envelope:
- discoloration outside?
- crystallization on the package or envelope?
- strange odors or oily stains?
- powder or powder-like residue on the outside?
- protruding wires or aluminum foil?
- excessive packaging material (masking tape, string, etc.)?
- lopsided or lumpy appearance?
- excessive weight?
- excessive postage?
- postmark conflicting with return address?
- restrictive endorsements such as "Personal" or "Confidential"?
- poorly typed or handwritten address?
- incorrect titles?
- titles without names?
- common words misspelled?
- missing a return address?
- addressed to someone who has left the company?
_________________________________	________________

Inspector	Date


Materials Handling

	YES	NO
Is there safe clearance for equipment through aisles and doorways?
Are aisles designated, permanently marked, and kept clear to allow unhindered passage?
Are motorized vehicles and mechanized equipment inspected daily or before use?
Are vehicles shut off and brakes set before loading or unloading?
Are containers of combustibles or flammables, when stacked while being moved, always separated by dunnage sufficient to provide stability?
Are dockboards (bridge plates) used when loading or unloading operations are taking place between vehicles and docks?
Are trucks and trailers secured from movement during loading and unloading operations?
Are dock plates and loading ramps constructed and maintained with sufficient strength to support imposed loading?
Are hand trucks maintained in safe operating condition?
Are chutes equipped with sideboards of sufficient height to prevent the materials being handled from falling off?
Are chutes and gravity roller sections firmly placed or secured to prevent displacement?
At the delivery end of the rollers or chutes, are provisions made to brake the movement of the handled materials?
Are pallets visually inspected before being loaded or moved?
Are hooks with safety latches or other arrangements used when hoisting materials so that slings or load attachments will not accidentally slip off the hoist hooks?
Are securing chains, ropes, chock blocks, and slings adequate for the job to be performed?
When hoisting material or equipment, are provisions made to assure that no one will be passing under the suspended loads?
Are Material Safety Data Sheets available to employees handling hazardous substances?
_________________________________	________________

Inspector	Date


Medical Services and First Aid

	YES	NO
After being offered or conditionally offered a job, is each applicant required to have a pre-employment physical examination that follows Americans with Disabilities Act regulations?
Is there a hospital, clinic, or infirmary for medical care at or near the workplace?
If medical and first aid facilities are not at or near the workplace, is at least one employee on each shift currently qualified to render first aid?
Are medical personnel readily available for advice and consultation on matters of employees' health?
Are emergency phone numbers posted?
Are suitable commercial first aid kits easily accessible to each work area?
Are first aid kits inspected and replenished at regular intervals?
Have necessary modifications and physician approval been obtained for special hazards and conditions?
Are means provided for quick drenching or flushing of the eyes and body in areas where corrosive liquids or materials are handled?
Are any employees exposed to infectious body fluids?
Are any employees required to render first aid?
If the "YES" box was checked for either of the last two questions, has a written Bloodborne Pathogens Plan been developed?
Have exposed employees been offered the hepatitis B vaccine?
Are all accidents and injuries that require more than first aid listed on the appropriate OSHA Log?
_________________________________	________________

Inspector	Date


Noise

	YES	NO
Are continuous noise levels in the workplace kept below 85 decibels (dBA)?
Is there an ongoing preventive health program to educate employees in safe levels of noise exposures, effects of noise on their health, and the use of personal protection?
Have work areas been identified and posted where noise levels make voice communication between employees difficult?
Are noise levels being measured using a sound level meter or an octave band analyzer, and are records being kept?
Where engineering controls are determined not to be feasible, are administrative controls (e.g., worker rotation) being used to minimize individual employee exposure to noise?
Is approved hearing protective equipment (noise-attenuating devices) available to every employee working in noisy areas?
Has isolating noisy machinery from the rest of the operation been tried?
If ear protectors are used, are employees properly fitted and instructed in their use?
Are employees in high-noise areas given periodic hearing tests to ensure that there is an effective hearing protection system?
Are engineering controls in operation?
Are administrative controls applied where feasible?
Are administrative controls and regulations observed?
Is hearing protection provided where sound levels exceed standards?
Are employees wearing approved hearing protection that, if required, is properly inserted in the ear canal?
_________________________________	________________

Inspector	Date


Offices

	YES	NO
Do floors have non-slippery surfaces without excessive polish?
Are there no holes or depressions in floors?
Are rugs in halls or offices free of holes and tears, and are they nonskid?
Are electrical equipment cords kept off walkways?
Are aisles free of obstructions, including electrical outlets?
Are stairwells and exits properly lighted?
Are light switches and cover plates in place?
Are unsafe ladders or trolleys taken out of use?
Is the general housekeeping good?
Are contents of filing cabinets arranged so that they are not top-heavy?
Is lifting, including opening of windows, performed safely?
Are pins, knives, cutters, and staplers used correctly?
Are fire escape doors unlocked and free for exit?
Is the correct type and placement of fire extinguishers used?
Are there no fire hazards from cigarettes?
Is there safe storage of flammables?
Are glass doors frosted or do they have lettering or decals?
Is running, crowding, or jamming of revolving doors prohibited?
Are furniture or accessories kept free of slivers or ragged edges?
Are there persons trained in hazard communication standards?
Are there first aid facilities?
Are electrical fans properly guarded?
Is there adequate ventilation?
_________________________________	________________

Inspector	Date


Personal Protective Equipment

	YES	NO
Is personal protective equipment (PPE) used only after engineering and administrative controls are first used to eliminate or control any hazards?
Has a hazard assessment been performed to identify all hazards for which PPE is needed?
Are employees properly trained in PPE procedures (i.e., when to wear PPE, how to adjust it, and what PPE is necessary for each job or task)?
Is PPE properly selected and fitted to each employee for each job?
Are proper signs and instructions posted at eye baths?
Is adequate emergency rescue equipment available?
Are protective goggles or face-shields provided and worn where there is any danger of flying particles, corrosive materials, or blood or other potentially infectious materials?
Are approved safety glasses required to be worn at all times in areas where there is risk of eye injuries such as punctures, abrasions, contusions, or burns?
Are employees who need corrective lenses (glasses or contacts) and who are exposed to harmful conditions in their work environment required to wear approved safety glasses or protective goggles or to follow other medically approved precautionary procedures?
Are protective gloves, aprons, shields, or other means provided against cuts, corrosive liquids, and chemicals?
Are hard hats provided and worn where danger of falling objects exists?
Are hard hats inspected periodically for damage to the shell and suspension system?
Where special equipment is needed for electrical workers, is it provided and worn?
Is appropriate foot protection required where there is the risk of foot injury from falling objects; hot, corrosive, or poisonous substances; or crushing or penetrating actions?
Are approved respirators provided for regular or emergency use where needed?
Is all protective equipment maintained in sanitary condition and ready for use?
Are eye-wash facilities and a quick drench shower located within work areas where employees are exposed to corrosive materials that could cause injury?
If food and beverages are consumed on the premises, are they eaten in areas where there is no exposure to toxic materials or other health hazards?
Is protection against the effects of occupational noise exposure provided when sound levels exceed those of the OSHA noise standard?
Are adequate work procedures, protective clothing, and equipment provided and used when cleaning up spilled toxic or otherwise hazardous materials or liquids?
Are there appropriate procedures for disposing of or decontaminating PPE that contains blood or other potentially infectious materials?
Is there a written policy with provisions for discipline for not using PPE?
_________________________________	________________

Inspector	Date


Piping Systems

	YES	NO
Are outlets or taps for pipes carrying nonpotable water marked to indicate that water is unsafe for drinking, washing, or personal use?
Have asbestos-covered pipelines been identified?
If hazardous substances (e.g., gas, argon) are transported through aboveground piping, is each affected pipeline identified?
When pipelines carrying hazardous substances are identified by colored paint:
- are all visible parts on the lines clearly identified?
- is the color code posted in all necessary locations?
When pipelines carrying hazardous substances are identified by color-painted bands or tapes, are these:
- located at reasonable intervals?
- located at each outlet, valve, or connection?
If the pipeline's contents are identified by name or abbreviation, is the information readily visible on the pipe near each valve or outlet?
When pipelines carrying hazardous substances are identified by tags:
- are the tags constructed of durable material?
- is the message clearly and permanently marked?
- are the tags installed at each valve or outlet?
If pipelines are heated by electricity, steam, or another external source, are suitable warning signs or tags placed at unions, valves, and other serviceable parts of the system?
_________________________________	________________

Inspector	Date


Portable Ladders

	YES	NO
Are all ladders maintained in good condition?
Specifically:
- Are joints between steps and side rails tight?
- Are all hardware and fittings securely attached?
- Are movable parts operating without binding or undue play?
Are nonslip safety feet provided on each ladder?
Are nonslip safety treads provided on each step of each ladder?
Are ladder rungs and steps free of grease and oil?
Is it prohibited to place a ladder in front of doors opening toward the ladder except when the door is blocked open, locked, or guarded?
Is it prohibited to place ladders on boxes, barrels, or other unstable bases to obtain additional height?
Are employees instructed to face the ladder when ascending or descending?
Are employees prohibited from using ladders that are broken, are missing steps or rungs, have broken side rails, etc.?
Are employees instructed not to use the top step of ordinary stepladders as a step?
When a portable rung ladder is used to gain access to elevated platforms, roofs, etc., does the ladder always extend at least three feet above the elevated surface?
When portable rung or cleat-type ladders are used, is it required that the base be placed to prevent slipping, or is the base lashed or otherwise held in place?
Are portable metal ladders legibly marked with signs reading "CAUTION - Do Not Use Around Electrical Equipment" or equivalent wording?
Are employees prohibited from using ladders as braces, skids, or gin poles, or from using them for other than their intended purposes?
Are employees instructed to adjust extension ladders only while standing at the base (not while standing on the ladder or from a position above the ladder)?
Are all metal ladders inspected for damage?
Are the rungs of ladders uniformly spaced at 12 inches, center to center?
_________________________________	________________

Inspector	Date


Portable (Power-Operated) Tools and Power Equipment

	YES	NO
Are grinders, saws, and similar equipment provided with appropriate safety guards?
Are power tools used with the shield or guard recommended by the manufacturer?
Are portable circular saws equipped with guards above and below the base shoe?
Are circular saw guards checked to make certain that they do not leave the lower portion of the blade unguarded?
Are rotating or moving parts of equipment guarded?
Are all cord-connected, electrically operated tools and equipment either effectively grounded or double-insulated?
Are effective guards in place over belts, chains, pulleys, sprockets, etc., on concrete mixers, air compressors, etc.?
Are portable fans provided with full guards or screens having openings 1/2 inch or less?
Is hoisting equipment available and used for lifting heavy objects and are hoist ratings and characteristics appropriate for the task?
During construction, are ground-fault circuit interrupters provided on temporary electrical circuits of 15 or 20 amps?
Are pneumatic and hydraulic hoses on power-operated tools checked regularly for deterioration or damage?
_________________________________	________________

Inspector	Date


Posting

	YES	NO
Is the required OSHA workplace poster displayed in a prominent location where employees are likely to see it?
Are all emergency telephone numbers posted where they can be readily found in case of emergency?
Where employees may be exposed to any toxic substances or harmful physical agents, has appropriate information been posted concerning employee access to:
- medical and exposure records;
- Material Safety Data Sheets (MSDSs); and
- Hazard Communication Plan or other written safety plans required by OSHA?
Are signs concerning exiting from buildings, room capacities, floor loading, or exposure to x-ray, microwave, or other harmful radiation or substances posted where appropriate?
Is the summary of Occupational Illnesses and Injuries (Form 300A) posted in February?
_________________________________	________________

Inspector	Date


Potentially Hazardous Chemicals

	YES	NO
Is an MSDS available for all chemicals or other federally listed hazardous materials?
Is a written Hazard Communication Plan prepared and available?
Are employees trained in the proper handling of each chemical?
Are there labels on all suppliers' drums and chemicals?
Are there labels on in-plant transfer containers?
Are adequate storage cabinets provided with proper venting?
Are there proper absorbent materials on hand for spills?
Are drums or tanks properly bonded and grounded?
Are containers inspected for corrosion?
_________________________________	________________

Inspector	Date


Powder-Actuated Tools

	YES	NO
Are employees who operate powder-actuated tools trained in their use and do they each carry a valid operator's card?
Is each powder-actuated tool stored in its own locked container when not being used?
Is a sign at least 7 inches by 10 inches with boldface type reading "POWDER-ACTUATED TOOL IN USE" conspicuously posted when the tool is being used?
Are powder-actuated tools left unloaded until they are actually ready to be used?
Are powder-actuated tools inspected for obstructions or defects each day before use?
Do powder-actuated tool operators have and use appropriate personal protective equipment such as hard hats, safety goggles, safety shoes, and ear protectors?
_________________________________	________________

Inspector	Date


Power Systems - Electrical

	YES	NO
Are electrical control panels clearly identified and secured?
Do only certified electrical specialists have access to panels?
Is grounding tested?
Are there explosion-proof fixtures in designated areas?
Are there any exposed conductors at rear of switchboard?
Are flexible extension cords free of fraying and splices?
Are electrical specialists properly trained in the operation and maintenance of this equipment?
_________________________________	________________

Inspector	Date


Power Systems - Hydraulic

	YES	NO
Are pressure lines clearly identified?
Are maintenance procedures checked for nicks, dents, and wearing in lines?
Is pressure regulated within limits?
Are emergency stops fully operational?
Are mechanics and tradesmen properly trained in the operation of these systems?
_________________________________	________________

Inspector	Date


Power Systems - Mechanical

	YES	NO
Is there proper guarding of any nip points, rotating collars, cams, chucks, couplings, clutches, shafts, flywheels, blot ends, and key ends?
Are emergency stops fully operational?
Is there adequate arrangement for oiling and greasing?
Is there correct adjustment of the work rest device on grinding wheels?
Is the vent hood in place and ventilation operational for grinding wheels?
Are mechanics, tradesmen, and helpers properly trained in the operation of these systems?
_________________________________	________________

Inspector	Date


Recordkeeping

	YES	NO
Are all occupational injuries and illnesses, except minor injuries requiring only first aid, being recorded as required on the appropriate OSHA Log? (See Chapter 4 for detailed instructions.)
Are employee medical records and records of employee exposure to hazardous substances or physical agents up-to-date?
Have arrangements been made to maintain required records for the legal period of time for each specific type of record? (Some EPA records must be maintained for at least 40 years.)
Are all permits and records up-to-date (EPA ID number, LP gas, elevators, etc.)?
_________________________________	________________

Inspector	Date


Safety and Health Plan

(Note: A safety and health plan is an important tool in accident prevention and employee safety. In addition, individual states may require such a plan for all employers, for employers above a certain size, or for employers that have poor safety records. This checklist is not intended to comply with specific requirements of individual states. States may have requirements in addition to or different from those in the following checklist.)

	YES	NO
Is top management completely committed to the safety and health plan?
Have specific safety improvement goals been established?
Is there a system in place for hazard identification and control?
Are all accidents and near misses investigated?
Is employee involvement in health and safety encouraged?
Is occupational safety and health training provided to workers and supervisors?
Is a record kept of each employee's safety training, including his or her name, training dates, types of training, and training provided?
Is the safety and health plan periodically reviewed and are necessary changes and revisions made?
_________________________________	________________

Inspector	Date


Safety Committees

(Note: A safety committee can be an important tool in accident prevention and employee safety. In addition, individual states may require such a committee for all employers, for employers above a certain size, or for employers that have poor safety records. This checklist is not intended to comply with specific requirements of individual states. States may have requirements in addition to or different from those in the following checklist.)

	YES	NO
Is there an active safety committee with equal numbers of management and employee representatives?
Does the committee involve all workers in the safety and health program?
Does the committee meet at least monthly (quarterly for office environments)?
Does the committee conduct quarterly hazard identification surveys?
Does the committee review results of periodic, scheduled worksite inspections?
Has the committee formalized an accident investigation procedure?
Does the committee review all accident and near-miss investigations and submit recommendations to prevent future incidents?
Is a written record of safety committee meetings distributed to affected employees and maintained for management review?
Are safety committee minutes posted each month and kept for three years?
_________________________________	________________

Inspector	Date


Sanitizing Equipment and Clothing

	YES	NO
Is personal protective clothing or equipment that employees are required to wear or use of a type that is easily cleaned and disinfected?
Are employees prohibited from interchanging personal protective clothing or equipment, unless it has been properly cleaned?
Are machines and equipment that process, handle, or apply materials that could cause injury to employees cleaned and/or decontaminated before being overhauled or placed in storage?
Are employees prohibited from smoking or eating in any area where potentially harmful contaminants are present?
When employees are required to change from street clothing into protective clothing, is a clean changing room with separate storage facilities for street and protective clothing provided?
Are employees required to shower and wash their hair as soon as possible after a known contact has occurred with a carcinogen?
When equipment, materials, or other items are taken into or removed from a carcinogen-regulated area, is it done in a manner that will not contaminate nonregulated areas or the external environment?
_________________________________	________________

Inspector	Date


Scaffolds or Platforms

	YES	NO
Are guardrails not less than 2 inches by 4 inches with midrail of 1 inch by 4 inches or equivalent?
Are guardrails at least 36-inches high and no more than 42 inches?
Is there nonskid flooring?
Are scaffolds and platforms level and plumb?
Is there safe access to platforms?
Are there four-inch toeboards around all sides of platform?
Are the working platforms at least two-feet wide?
Are all access gates self-closing and locking?
Is there any accumulation of tools and materials on scaffolds and platforms?
_________________________________	________________

Inspector	Date


Spraying Operations

	YES	NO
Is adequate ventilation assured before spray operations are started?
Is mechanical ventilation provided when spraying operations are done in enclosed areas?
When mechanical ventilation is provided during spraying operations, is it arranged so that it will not circulate the contaminated air?
Is the spray area free of hot surfaces?
Is the spray area at least 20 feet from flames, sparks, operating electrical motors, and other ignition sources?
Are the portable lamps used to illuminate spray areas suitable for use in a hazardous location?
Is approved respiratory equipment provided and used when appropriate during spraying operations?
Do solvents used for cleaning have a flash point of 100°F or more?
Are fire control sprinkler heads kept clean?
Are "NO SMOKING" signs posted in spray areas, paint rooms, paint booths, and paint storage areas?
Is the spray area kept clean of combustible residue?
Are spray booths constructed of metal, masonry, or other substantial noncombustible material?
Are spray booth floors and baffles noncombustible and easily cleaned?
Is infrared drying apparatus kept out of the spray area during spraying operations?
Is the spray booth completely ventilated before using the drying apparatus?
Is the electric drying apparatus properly grounded?
Are lighting fixtures that are used to light spray booths (whether located outside or inside the spray booth) installed behind sealed clear panels?
Are electric motors for exhaust fans placed outside booths or ducts?
Are belts and pulleys inside the booth fully enclosed?
Do ducts have access doors to allow cleaning?
Do all drying spaces have adequate ventilation?
_________________________________	________________

Inspector	Date


Stairs

	YES	NO
Are stairs uniform in height and tread depth?
Is there grating-type tread on exterior stairs?
Are there platform levels to break long flights of stairs?
Is there storage of material on stairs?
Are stairs properly lighted?
Are stair treads in good repair?
Are there standard stair rails or handrails on all stairways with four or more risers?
Are all stairways at least 22 inches wide?
Do stairs have at least a 6 1/2-foot overhead clearance?
Do stairs angle no more than 50 degrees and no less than 30 degrees?
Are stairs of hollow-pan-type treads and landings filled with solid material to the proper sound level?
Are step risers on stairs uniform from top to bottom, with no riser spacing greater than 7 1/2 inches?
Are steps on stairs and stairways designed with or provided with a surface that renders them slip-resistant?
Are stairway handrails located between 30 and 34 inches above the leading edge of stair treads?
Do stairway handrails have at least 1 1/2 inches of clearance between the handrails and the wall or surface they are mounted on?
Are stairway handrails capable of withstanding a load of 200 pounds, applied in any direction?
Where stairs or stairways exit directly into any area where vehicles may be operated, are adequate barriers and warnings provided to prevent employees from stepping into the path of traffic?
Are stairway landings as long as they are wide (i.e., is the length of the landing at least equal to the width of the stairway)?
Is the vertical distance between stairway landings limited to 12 feet or less?
_________________________________	________________

Inspector	Date


Tire Inflation

	YES	NO
Is a safe practice procedure posted and enforced:
- where tires are mounted or inflated on drop-center wheels?
- where tires are mounted or inflated on wheels with split rims or retainer rings?
Does each tire inflation hose have a clip-on chuck with at least 24 inches of hose between the chuck and an in-line valve and gauge?
Does the tire-inflation control valve automatically shut off the air flow when the valve is released?
Is a tire-restraining device (such as a cage or rack) used while inflating tires mounted on split rims or rims using retainer rings?
Are employees strictly prohibited from taking a position directly over or in front of a tire while it is being inflated?
_________________________________	________________

Inspector	Date


Transporting Employees and Materials

	YES	NO
Do employees who operate vehicles on public thoroughfares have valid operator's licenses?
When seven or more employees are regularly transported in a van, bus, or truck, is the operator's license appropriate for the class of vehicle being driven?
Are vans, buses, or trucks that are used regularly to transport employees equipped with an adequate number of seats?
When employees are transported by truck, are provisions provided to prevent their falling from the vehicle?
Are vehicles used to transport employees in good repair and equipped with lamps, brakes, horns, mirrors, windshields, and turn signals?
Are transport vehicles provided with handrails, steps, stirrups, or similar devices that are placed and arranged so that employees can safely mount or dismount?
Are employee transport vehicles equipped at all times with at least two reflective-type flares?
In each employee transport vehicle, is a fully charged fire extinguisher maintained in good condition, with at least a 4 B:C rating (i.e., a four-pound fire extinguisher appropriate for all types of fires)?
When cutting tools or tools with sharp edges are carried in passenger compartments of employee transport vehicles, are they placed in closed boxes or containers that are secured in place?
Are employees prohibited from riding on top of any load that can shift, topple, or otherwise become unstable?
_________________________________	________________

Inspector	Date


Ventilation for Indoor Air Quality

	YES	NO
Does the heating, ventilation, and air conditioning (HVAC) system provide (at a minimum) the amount of outside air designed for the system at the time the building was constructed?
Is the HVAC system inspected at least annually and maintained in a clean and efficient manner?
Are efforts made to purchase furnishings or building treatments that do not give off toxic or offensive vapors?
Are indoor air quality complaints investigated and the results conveyed to employees?
_________________________________	________________

Inspector	Date


Ventilation for Work Areas

	YES	NO
Is each work area's ventilation system appropriate for the work being performed?
Are hoods properly connected to the exhaust system?
Do hoods draw air away from people?
Are clean-out ports for ducts provided?
Are maintenance clean-out schedules observed?
Are fans properly guarded?
_________________________________	________________

Inspector	Date


Ventilation of Harmful Substances

	YES	NO
Are exhaust systems equipped with the sufficient volume and velocity of air to gather and control dusts, fumes, mists, vapors, or gases and to carry them to a suitable point of disposal?
Are exhaust inlets and ducts designed, constructed, and supported to prevent collapse or failure of any part of the system?
Are clean-out ports or doors provided at intervals not exceeding 12 feet in all horizontal runs of exhaust ducts?
Where two or more different types of operations are being controlled through the same exhaust system, will the combination of substances being controlled constitute a fire, explosion, or chemical reaction hazard in the duct?
Is adequate replacement air provided to areas where exhaust systems are operating?
Does the source point for replacement air provide clean, fresh air that is free of contaminants?
Where two or more ventilation systems are serving a work area, is their operation such that one will not offset the functions of the other?
_________________________________	________________

Inspector	Date


Video Display Terminals (VDTs)

	YES	NO
Can the workstation be adjusted to ensure proper posture through:
- adjusting knee and hip angles for comfort?
- supporting heel and toes on the floor or a footrest?
- placing arms comfortably at the side with hands horizontal?
- supporting wrist with a padded surface?
Does the work area:
- provide enough leg, knee, and foot clearance from the edge of the work surface?
- provide space for thighs between chair seat and work surface?
- include armrests for lengthy typing and keystroking jobs?
- provide headsets for use if frequent telephone work is combined with hand tasks such as typing or using a calculator?
- have other input devices (e.g., mouse, printer) at same height as keyboard?
Does the chair:
- adjust easily from the seated position?
- have a padded seat approximately 18-inches wide?
- have a seat that adjusts in height (15 inches to 17 inches) and angle?
- use a waterfall design for the seat's front edge?
- have a backrest with lumbar support?
- have a stable base with appropriate casters for the flooring?
Is the keyboard:
- adjustable in height from the floor?
- detachable and outfitted with an adjustable slope?
- arranged so that workers keep their hands and wrists in a neutral position while working?
Is the monitor:
- equipped with brightness and contrast controls?
- equipped with a display screen that is flicker-free and clean?
- free of glare on the screen from lights or windows?
- capable of swiveling and tilting?
- between 18 and 30 inches from the operator?
- placed so that the text is at or slightly below eye height?
- placed so that the head can be kept in a neutral posture throughout most of the work shift?
Is the job organized so that:
- workers can change postures frequently?
- workers can perform different job tasks to provide needed breaks from intensive typing (at least 10 minutes after every hour of intensive typing and at least 15 minutes after every two hours of intensive typing)?
- workers receive training in ergonomics and necessary skills for properly adjusting their workstations?
_________________________________	________________

Inspector	Date


Waste Disposal

	YES	NO
Are special containers provided for different types of waste (oily rags, chemicals, scrap, garbage, etc.)?
Is food waste handled separately?
Where required, is waste properly labeled?
Are arrangements for external disposal satisfactory?
Are there approved disposal arrangements for hazardous waste?
_________________________________	________________

Inspector	Date


Welding, Cutting, and Brazing

	YES	NO
Are only authorized and trained personnel allowed to use welding, cutting, or brazing equipment?
Are compressed gas cylinders regularly examined for signs of defects, deep rusting, or leakage?
Are liquefied gases stored and shipped with the valve end up and with valve covers in place?
Are cylinders kept away from sources of heat?
Are signs reading: "DANGER - NO SMOKING, MATCHES, OR OPEN LIGHTS" or the equivalent posted?
Is the use of cylinders as rollers or supports prohibited?
Do empty cylinders have:
- appropriate markings?
- closed valves?
- valve-protection caps placed on them?
Are cylinders, cylinder valves, couplings, regulators, hoses, and apparatus kept free of oily or greasy substances?
Are regulators removed and valve-protection caps put in place before cylinders are moved (unless secured on special trucks)?
Do cylinders without fixed hand wheels have keys, handles, or nonadjustable wrenches on stem valves when in service?
Before a regulator is removed, is the valve closed, and then gas released from the regulator?
Is the open circuit (no load) voltage of arc welding and cuffing machines kept as low as possible (not in excess of the recommended limit)?
Are electrodes removed from the holders when not in use?
Is electric power to the welder required to be shut off when no one is in attendance?
Is suitable fire extinguishing equipment available for immediate use?
Is the welder forbidden to coil or loop the welding electrode cable around his or her body?
Are arc and electrode lead cables inspected frequently and replaced when needed?
Are means for connecting cable lengths adequately insulated?
When the welding object cannot be moved and fire hazards cannot be removed, are shields used to confine heat, sparks, and slag?
Are fire watchers assigned when welding or cutting is performed where a dangerous fire might develop?
When welding is done on all-metal walls, are precautions taken to protect combustibles on the other side?
Before hot work begins, are drums, barrels, tanks, and other containers thoroughly cleaned and tested to remove any substances that could explode, ignite, or produce toxic vapors?
Are employees exposed to hazards from welding, cutting, or brazing operations protected by personal protective equipment and clothing?
Do eye protection helmets, hand shields, and goggles meet appropriate standards?
Is a check made for adequate ventilation where welding or cutting is performed?
For welders in confined spaces:
- are means available for their quick removal in an emergency?
- are environmental monitoring tests performed to ensure worker safety?
_________________________________	________________

Inspector	Date


Yard and Roads

	YES	NO
Are there no obstructions or broken surfaces on roads or sidewalks?
Is there good housekeeping in yard areas?
Are potentially combustible materials stored out of direct sunlight?
Are there appropriate traffic signs and markers?
Are rail siding beds in good repair and free of obstruction?
_________________________________	________________

Inspector	Date


Table of Contents

Digest of OSHA Safety Standards for General Industry

Introduction

Abatement, Generally

Abatement Certification, Sample Letter

Abrasive Blasting

Abrasive Grinding

Abrasive Wheels, Portable

Accident and Illness Recordkeeping Requirements

Accident Reporting to OSHA

AIDS (HIV)

Aisles and Passageways

Asbestos

Battery Changing and Charging - Forklifts

Belt Sanding Machines

Bloodborne Pathogens

Boilers - No OSHA Standard

Carbon Monoxide

Cold Stress

Compressed Air

Compressed Gas

Confined Spaces

Consultative Services

Control of Hazardous Energy (Lock-Out/Tag-Out)

Cranes, Hoists, and Other Lifting Equipment

Dip Tanks

Dockboards

Drinking Water

Electrical Safety-Related Work Practices

Electrical Utilization Equipment

Elevators, Dumbwaiters, Escalators, and Moving Walks

Emergency Action Plans

Employee Complaints

Employee Consultation with OSHA Inspector

Ergonomics

Exits

Explosives and Blasting Agents

Eye and Face Protection

Eye Wash

Fall Arrest Systems

Fall Protection

Fan Blades

Fines and Penalties, Adjustments

Fines and Penalties, Classification and Assessment

Fines and Penalties, Criminal Offenses

Fire Doors - No OSHA Standard

Fire Extinguishers

Fire Safety

First Aid

Flammable Liquids

Floor Load Limits

Floor Openings and Open Sides

Foot Protection

Forklift Batteries, Changing and Charging

Forklift Operations

General Duty Clause

Hand and Power Tools

Hand Protection

Hazard Assessment

Hazard Communication

Hazardous Chemicals

Hazardous Waste Operations

Head Protection

Heat Stress

Hepatitis B Vaccination

Home Worksites

Hooks

Housekeeping

Infectious Materials

Inspections and Investigations

Ladders, Fixed

Ladders, Portable

Lead

Light Guards

Lighting

Lock-Out/Tag-Out

Lunch Rooms

Machine Guarding

Machinery, Fixed

Material Safety Data Sheets

Mats, Insulating

Mechanical Power Presses

Medical Records, Access and Retention

Medical Services and First Aid

Multi-Employer Worksites

Musculoskeletal Disorders (MSDs)

Noise Exposure

Open Pits and Tanks, Covers and Guardrails

OSHA Poster

OSHA Survey

Personal Protective Equipment (PPE)

Pneumatic Power Tools

Power Transmission Equipment, Guarding

Pressure Vessels, Portable Unfired

Process Safety Management of Highly Hazardous Chemicals

Radiation

Railings

Respiratory Protection

Revolving Drums

Ropes

Saws, Band

Saws, Portable Circular

Saws, Radial

Saws, Swing or Sliding Cut-Off

Saws, Table

Scaffolds

Self-Audits

SHARP Participation

Sign Design

Site-Specific Targeting (SST) Plan

Spray Finishing Operations

Stairs, Fixed Industrial

Storage

Tags - Color Coding

Tanks, Open-Surface

Toeboards

Toilets

Trash

Ultraviolet (UV) Radiation

Video Display Terminals (VDTs)

Voluntary Protection Program (VPP)

Washing Facilities

Welding

Welding - Compressed Gas Cylinders

Welding - Confined Spaces

Woodworking Machinery

Workplace Security


Introduction

Digest of OSHA Safety Standards for General Industry

This digest provides employers with the Occupational Safety and Health Administration (OSHA) general industry standards most often violated by businesses. These standards involve the most overlooked and, in some cases, the most dangerous situations an employer will encounter. Employers in particular industries, such as construction or shipbuilding, may be subject to additional or different standards.

The standards discussed in this chapter generally can be found in Volume 29 of the Code of Federal Regulations (CFR), Part 1910. Each summary contains a citation for the regulation on which the summary is based. In the event of any legal questions involving an OSHA standard, an employer should refer to the regulation as published by OSHA. The summaries in this chapter are intended as a working checklist for employers and cannot be substituted for the full regulation (particularly if appealing an OSHA citation). The summaries are written in clear "memo English" and are intended to help employers comply with OSHA standards.

A separate chapter (Chapter 1) outlines OSHA's rules on inspections, citations, and contests, as well as the basic rights and responsibilities of both employers and employees. It is recommended that employers review Chapter 1 to gain a basic understanding of OSHA before reading the detailed information on specific standards in this digest.

Separate chapters discuss topics of special importance in greater detail. Chapter 2 addresses the Hazard Communication Standard, which is the most frequently cited of all the OSHA standards. Chapter 7 addresses OSHA's many training requirements. Chapter 8 briefly discusses some of the unique standards in states with OSHA-approved plans.


Abatement, Generally

Abatement is the correction of a safety or health hazard for which an employer has received an OSHA citation. OSHA requires employers with cited hazards to abate them as soon as possible. Otherwise, the employer will receive an additional citation for failure to eliminate the hazard.

•	Effect of Employer Contest: By contesting the designated abatement or the citation itself, the employer delays the beginning of the abatement period until the Occupational Safety and Health Review Commission's order becomes final (unless the contest is in bad faith or is solely for delay).

•	No Written Proof Required for "Moderate"/"Low Gravity" Hazards: Employers generally do not have to provide written proof that they have abated "moderate" or "low gravity" hazards (unless the employer has within the previous three years received a citation for a willful violation or for failure to abate a hazard; see Fines and Penalties, Classification and Assessment).

•	Abatement Certification Letter: A simple one-page certification letter is all that is generally needed for non-serious violations when written proof is required (see Abatement Certification, Sample Letter).

•	Notification of Employees: Employers must inform employees of abatement efforts (see Posting Requirements).

•	Abatement Plans and Progress Reports: These may be required for more serious violations with abatement periods in excess of 90 days.

29 CFR 1903.19


Abatement Certification, Sample Letter

A sample abatement certification letter, which is generally suitable for proof of the abatement of non-serious violations as well as some serious violations is set forth below. See Abatement, Generally.

<date>

To:	U.S. Department of Labor - OSHA

<address of the area office (on the citation)>

From:	<name and address of company>

The hazard referenced in Inspection Number _______ for the violation identified as Citation ________ and Item _________ was corrected on ___________(date) by __________________(list the method used).

The hazard referenced in Inspection Number _______ for the violation identified as Citation ________ and Item _________ was corrected on ___________(date) by __________________(list the method used).

The hazard referenced in Inspection Number _______ for the violation identified as Citation ________ and Item _________ was corrected on ___________(date) by __________________(list the method used).

I attest that the information contained in this document is accurate and that the affected employees and their representatives have been informed of the abatement activities described in this certification.

Sincerely,

<signature>

<typed name>


Abrasive Blasting

Blast-cleaning nozzles must be equipped with an operating valve that is held open manually (deadman control). A support must be provided on which the nozzle may be mounted when not in use.

29 CFR 1910.244(b)

All blast-cleaning enclosures must be exhaust ventilated. A continuous inward flow of air must be maintained at all openings in the enclosure during the blasting operation.

29 CFR 1910.94(a)

Abrasive-blasting operators must wear respirators when working inside of blast-cleaning rooms.

29 CFR 1910.94(a)


Abrasive Grinding

Rule

Abrasive wheels can be used only on machines that have safety guards.

29 CFR 1910.215(a)(1)

Exceptions

•	wheels used for internal work while within the work being ground

•	mounted wheels used in portable operations two inches and smaller in diameter

•	type 16, 17, 18, 18R, and 19 cones, plugs, and threaded hole pot balls, where the work offers protection

Rule

An abrasive wheel safety guard must cover the spindle end, nut, and flange projections.

29 CFR 1910.215(a)(2)

Exceptions

•	The safety guard can be constructed so that the spindle end, nut, and outer flange can remain exposed during operations in which the work provides a suitable measure of protection to the operator.

•	The side covers of the guard may be omitted when the side of the wheel is entirely covered while working.

•	The spindle end, nut, and outer flange may be exposed on machines designed as portable saws.

Rule

Abrasive wheel safety guards for bench and floor stands should not expose the grinding wheel. The protecting member must be adjustable for variations in wheel size. The distance between the wheel and the guard cannot exceed 1/4 inch.

29 CFR 1910.215(b)(9)

Machines designed for a fixed location must be securely anchored to prevent movement in normal operations.

29 CFR 1910.212(b)

An adjustable work-rest of rigid construction must be used to support the work. The work-rest must be kept adjusted closely to the wheel with a maximum clearance of 1/8 inch.

29 CFR 1910.215(a)(4)


Abrasive Wheels, Portable

Rule

Abrasive wheels may be used only on machines that have safety guards.

29 CFR 1910.243(c)

Exceptions

•	wheels used for internal work while within the work being ground

•	mounted wheels used in portable operations two inches and smaller in diameter

•	types 16, 17, 18, 18R, and 19 cones, plugs, and threaded hole pot balls, where the work offers protection

Rule

A safety guard must cover the spindle end, nut, and flange projections. The safety guard must be mounted to maintain proper alignment with the wheel. The strength of the fastenings must exceed the strength of the guard.

29 CFR 1910.243(c)(1)(ii)

Exceptions

•	The safety guard can be constructed so that the spindle end, nut, and outer flange can remain exposed during operations in which the work provides a suitable measure of protection to the operator.

•	Safety guards may be omitted on portable machines designed for, and used with, types 6, 11, 27, and 28 abrasive wheels, cutting-off wheels, and truck-pointing wheels.

•	The side covers of the guard may be omitted when the side of the wheel is entirely covered while working.

Rule

Safety guards used on machines known as right-angle-head or vertical portable grinders must have a maximum exposure angle of 180 degrees. Guards must be located between the operator and the wheel during use. Adjustments of the guard must cause pieces of a broken wheel to be deflected away from the operator.

29 CFR 1910.243(c)(3)


Accident and Illness Recordkeeping Requirements

OSHA accident and illness recordkeeping requirements are listed in Overview of Recordkeeping Requirements.


Accident Reporting to OSHA

OSHA accident reporting standards are discussed in Accident Reporting Requirements.


AIDS (HIV)

AIDS (HIV) is a bloodborne pathogen. Bloodborne pathogens are discussed in the digest topic, Bloodborne Pathogens.

29 CFR 1910.1030


Aisles and Passageways

Clearance must be allowed for aisles where mechanical handling equipment is used. This includes loading docks, through doorways, and wherever turns or passage must be made.

All aisles and passageways will be kept clear and in good repair with no obstruction that could create a hazard.

Permanent aisles and passageways will be appropriately marked.

Covers or guardrails will be provided for open pits, tanks, vats, ditches, etc.

29 CFR 1910.22


Asbestos

The asbestos regulations require employers to make sure that employees are not exposed above permissible exposure limits (PELs). In general, employers must perform initial and periodic monitoring to make sure that PELs are not exceeded. Employees must receive timely written notice of the monitoring.

Employers must also use engineering and work practice controls to reduce employee exposure to below the PELs. Where these are insufficient, the employer must supplement them with appropriate respiratory protection. Where asbestos concentrations exceed PELs, employers are required to establish regulated areas. These must be marked and must limit access to authorized persons. Persons who enter regulated areas must receive and wear respirators.

For buildings built no later than 1980, the owner must assume that all thermal system insulation, sprayed and troweled-on surfacing materials, and asphalt and vinyl floor covering contain asbestos. Owners and employer occupants must communicate asbestos hazards to their employees and give appropriate training on how to avoid making the asbestos airborne and how to take necessary safety precautions.

Permissible Exposure Limits (PELs)

Employers must make sure that employee exposure to asbestos does not exceed the following limits:

•	Time-Weighted Average Limit (TWA): The employer must make sure that no employee is exposed to an airborne concentration of asbestos over 0.1 fiber per cubic centimeter of air as an eight-hour time-weighted average (TWA).

•	Excursion Limit: The employer must make sure that no employee is exposed to an airborne concentration of asbestos over 1.0 fiber per cubic centimeter of air (1 f/cc) as averaged over a sampling period of 30 minutes.

29 CFR 1910.1001(c)

Wet State

As far as practical, asbestos must be worked in a wet state to prevent employee exposure to asbestos in excess of the TWA or excursion limit.

No asbestos cement, mortar, coating, or similar material containing asbestos may be removed from bags, cartons, or containers without one of the following preventing release of airborne fibers:

•	wetting

•	enclosure

•	ventilation

29 CFR 1910.1001(f)(1)

Compliance Program

Where the TWA or excursion limit is exceeded, the employer must establish a plan to reduce employee exposure. If engineering and work practice controls are incapable of doing so, the employer must provide respirators and institute a respirator plan. Respirators must also be used in emergencies and during the interval to install or implement feasible engineering and work practice controls. In addition, construction employers must inform employees who are required to wear respirators that the employees may require the employer to provide a powered air-purifying respirator instead of a negative-pressure respirator.

Training requirements for working with asbestos are discussed in Asbestos.


Battery Changing and Charging - Forklifts

This subject is discussed in the digest topic, Forklift Batteries, Changing and Charging.


Belt Sanding Machines

Belt sanding machines must be provided with guards at each nip point where the sanding belt runs into a pulley.

The unused run of the sanding belt must be guarded.

29 CFR 1910.213(p)(4)


Bloodborne Pathogens

Bloodborne pathogens regulations attempt to limit occupational exposure to blood and other potentially infectious materials. Limiting exposure helps minimize the risk from bloodborne pathogens that could lead to disease or death.

The standard applies to all employers whose employees can "reasonably anticipate" contact with blood and other infectious materials while performing their job duties. The standard itself does not specify occupations in which exposures are likely to occur, although OSHA did provide a list in its 2001 compliance directive (see subsection below).

Covered employers must do all of the following:

•	develop a bloodborne pathogens plan that includes engineering controls and work practices to minimize employee exposure

•	make a report of all exposure incidents before the end of the work shift in which the incident occurs and include all the following in the report:

-	the name of all first aid providers

-	a description of the incident's circumstances

-	the date and time of the incident

•	offer a confidential medical evaluation and follow-up to any employee who has suffered exposure

2000 Needlestick Safety and Prevention Act

In October of 2000, Congress passed the Needlestick Safety and Prevention Act. Under the Act and its implementing regulations, employers must do all of the following:

•	consider safer medical devices such as Sharps with Engineered Sharps Injury Protection (SESIPs) and needleless systems for use as "engineering controls"

•	solicit and document input regarding engineering and work practice controls from non-managerial employees who:

-	are responsible for direct patient care, and

-	may be injured from contaminated sharps

•	review the plan annually to update and document technological changes that eliminate or reduce bloodborne pathogens exposure

•	keep a sharps injury log for percutaneous injuries from exposure incidents with contaminated sharps, including:

-	the type and brand of device,

-	the department and area involved, and

-	an explanation of how the incident occurred

OSHA Directives

OSHA has issued several directives regarding enforcement of the Bloodborne Pathogens Standard. The most recent directive addresses a number of important matters, including the following:

•	An illustrative list was formulated of workers who are likely to be covered by the OSHA standard, including:

-	doctors, nurses, physician's assistants, and other employees in clinics, physicians' offices, hospitals, and other health care settings

-	dentists, dental technicians, and dental hygienists

-	employees of clinics, tissue banks, blood banks, and diagnostic labs

-	housekeepers in health care and other facilities

-	personnel in hospital laundries or commercial laundries that service health care or public safety personnel

-	employees designated to provide emergency first aid

-	home health care, nursing home, and hospice employees

-	staff of institutions for the developmentally disabled

-	funeral home and mortuary employees

-	employees of HBV and HIV research facilities

-	employees of substance abuse clinics

-	custodial workers who clean up contaminated sharps or spills of blood or other bodily fluids

-	employees who handle regulated waste

-	paramedics and other medical emergency personnel

-	police officers, fire fighters, and personnel of correctional institutions

-	maintenance workers in health care facilities

-	medical equipment service and repair personnel

•	Covered employers must inform employees that bloodborne pathogens are not limited to HIV and HBV, but also include HCV, the spirochete that causes syphilis, and other disease-causing organisms.

•	Engineering controls and work practices must be used to reduce occupational exposure to the greatest extent possible; an employer is to use personal protective equipment (PPE) only if the hazard cannot first be eliminated by engineering controls and work practices.

•	Employers need to protect their employees from the dangers of overfilled sharps containers. Nationwide, hundreds of employees have been injured while attempting to put sharps into overfilled containers. To help employees avoid overfilling containers, employers should:

-	place containers at a height where employees can check their contents; or

-	purchase containers that have a transparent window for viewing.

Related Topics

The various parts of the bloodborne pathogens regulations are found in Hepatitis B Vaccination and Infectious Materials.

29 CFR 1910.1030

Training requirements for bloodborne pathogens exposure control are discussed in Chapter 7, Bloodborne Pathogens. A sample Bloodborne Pathogens Exposure Control Plan is available from Summers Press in its Sample Safety Plans on CD.


Boilers - No OSHA Standard

Boiler design and construction is covered by the Code of Fire Pressure Vessels, Section I, ASME Boiler and Pressure Vessel Code of 1968. The following are good practice procedures and might be incorporated into future OSHA standards.

All boilers must be inspected on an annual basis. A recognized boiler inspection service is satisfactory evidence of acceptable installation and maintenance.

A valid boiler inspection certificate and the date of the last inspection must be conspicuously posted.

All boilers must be equipped with approved water columns, gauge-glass, and try cocks. Gauge-glass and water columns must be guarded to prevent breakage.

An emergency shutdown procedure recommended by the boiler manufacturer or insurance underwriter must be carried out when such a shutdown is required.


Carbon Monoxide

OSHA standards limit employee exposure to an average of 50 parts CO (carbon monoxide) per million parts of air during an 8-hour work shift in a 40-hour workweek. The risk of overexposure usually increases in winter when traditional sources of ventilation, such as windows, doors, and vents, are often closed because of cold weather.

To comply with the standard, employers must reduce CO to permissible levels or remove employees from the hazardous condition. Engineering and administrative controls are the preferred methods of preventing excessive CO levels. However, when these methods cannot achieve full compliance, personal protective equipment (e.g., respirators) must be used to protect employees.

29 CFR 1910.1000(a)(2); 1910.1000 TABLE Z-1


Cold Stress

To avoid a citation under the general duty clause, employers must protect workers from the dangers of cold stress. The following is a brief summation of some recent tips from OSHA for avoiding harmful effects from cold environments:

•	Aggravation Factors for Cold-Related Stresses:

-	inadequate clothing

-	consumption of alcohol, nicotine, caffeine, or certain medications

-	exhaustion, immobility, or elderliness

-	"wind chill" (a 40°F temperature is equal to 11°F if the wind velocity is 35 miles per hour)

•	Harmful Effects of Cold:

-	trench foot: tingling, itching, or burning of foot short of frostbite

-	frostbite: actual freezing of tissues, which can require amputation in severe cases

-	general hypothermia: impaired mental and muscular functions from dramatic drops in body temperature (the most extreme cases can result in heart failure and death)

•	Preventing Cold-Related Injuries:

-	personal protective clothing: recommended outer layer to break the wind; middle layer to absorb sweat, and inner layer to allow ventilation

-	engineering controls: on-site heat sources (e.g., air jets, radiant heaters), shields for drafty areas, heated shelters (for prolonged exposure to temperatures below 20°F), and thermal insulating material on equipment handles (for temperatures below 30°F)

•	Safe Work Practices:

-	allowing needed adjustment periods and necessary break periods

-	limiting exposure by minimizing outdoor activities in the cold and picking the warmest time of day to work

-	educating employees as to symptoms of cold-related stresses: heavy shivering, uncomfortable coldness, severe fatigue, drowsiness, and euphoria

-	ensuring that employees remain hydrated (drink plenty of fluids)

29 U.S.C. § 654(a)


Compressed Air

Compressed air used for cleaning may not exceed 30 pounds per square inch (psi). Chip guarding and personal protective equipment must be used while cleaning.

29 CFR 1910.242(b)

Compressed Air Drains and Traps

A drain pipe and valve must be installed at the lowest point of every air receiver to provide for the removal of oil and water. The receiver should be drained frequently to prevent the buildup of liquids. Note: This regulation does not apply to automotive repair services or any transportation equipment.

29 CFR 1910.169(a)(2)

Compressed Air Gauges and Valves

Every air receiver must be equipped with a pressure gauge and with one or more safety valves. The safety valves must be able to prevent pressure in the receiver from exceeding the receiver's maximum allowable working pressure by more than 10%. Note: This regulation does not apply to automotive repair services.

No valve of any type may be placed between the air receiver and its safety valves. All safety valves must be tested frequently and at regular intervals to determine whether they are in good condition.

29 CFR 1910.169(a)(3)

Chip Guards

Guarding must be provided in operations involving cleaning with compressed air. Effective guarding includes protective shields or barriers and personal protective equipment.

29 CFR 1910.242(b)


Compressed Gas

The in-plant handling, storage, and use of all compressed gases in cylinders, portable tanks, rail tank cars, or motor vehicle cargo tanks must be in accordance with the standards stated in the Compressed Gas Association Pamphlet P-1-1965.

29 CFR 1910.101

No person other than the gas supplier may attempt to mix gases in a cylinder.

29 CFR 1910.253(c)(5)(ii)(M)

A hammer or wrench may not be used to open cylinder valves. If valves cannot be opened by hand, the supplier must be notified. If a special wrench is required, it must be left in position on the stem of the valve while the cylinder is in use. This allows the fuel gas to be turned off quickly in case of an emergency.

29 CFR 1910.253(b)(5)(iii)(L)

For information on compressed gas cylinders used in welding, see Welding - Compressed Gas Cylinders. For information on training for workers who use liquefied petroleum (LP) gases, see Chapter 7, Liquefied Petroleum (LP) Gases.


Confined Spaces

Employers must develop a written safety plan to protect employees from the hazards of "permit-required confined spaces."

OSHA defines a "confined space" as an area that:

•	has adequate size and configuration for employee entry and work performance;

•	has limited means of entry or outlet; and

•	is not designed for continuous employee occupancy.

29 CFR 1910.146

A "permit-required confined space" is a confined space that:

•	has or could contain a hazardous atmosphere;

•	contains materials that could engulf a worker in the space;

•	could close in and trap or asphyxiate a worker; or

•	contains any other serious safety or health hazard.

29 CFR 1910.146

Recent Clarification

OSHA recently clarified the rules for permit-required confined spaces:

•	to require employers to consult with employees and their representatives concerning the confined space program

•	to require employers to allow authorized representatives (in addition to employees) the opportunity to observe any testing or monitoring of permit spaces

•	to improve employer selection of an off-site emergency rescue team by requiring:

-	that any rescue be "timely" based on the particular hazards and circumstances of the confined space;

-	that the employer assess the skill and competence of the prospective off-site rescue team through an initial evaluation and a performance evaluation; and

-	that the employer provide any designated off-site rescuers with information about its confined spaces and access to those spaces.

•	to allow employers more flexibility in determining where to attach retrieval lines to rescue workers (at any point for which the entrant will present the smallest possible point during removal, not just above the entrant's head or at the entrant's back near shoulder level)

Training and Safety Program Information

Training requirements for confined spaces are discussed in Chapter 7, Confined Spaces. A sample Confined Space Safety Plan is available from Summers Press in its Sample Safety Plans on CD.


Consultative Services

OSHA funds consultative services for employers at no charge through individual state agencies. These services are designed to help employers establish effective safety and health plans and to improve worker health and safety (see Getting Free Professional Assistance). These consultative services were first funded under the Reagan administration as a means of encouraging employers to comply with safety standards other than through the threat of fines and penalties. The program has since been codified through legislation.

Program Basics

The assistance is primarily provided at the employer's worksite, but off-site help may be provided by telephone and correspondence. Assistance may also be available at locations other than the employer's worksite, such as consultation project offices.

On-site consultation is conducted independently of OSHA enforcement activity, and the discovery of hazards does not require citation or penalties. However, the employer remains legally obligated to protect employees. Employers must act immediately to eliminate imminent dangers. In addition, any serious hazards that are identified by the consultant must be corrected within a reasonable time. Failure of the employer to properly respond to severe hazards requires the consultant to notify the OSHA enforcement authorities.

Inspection Exemption

Participating employers that meet certain conditions may receive a deferral (exemption) from inspection for a period of up to 18 months. This inspection exemption removes employers from OSHA's list of random ("programmed") inspections. However, it does not prevent the agency from inspecting because of an employee complaint or because of a reportable accident (see Accident Reporting Requirements).

29 U.S.C. § 670; 29 CFR 1908.1

2001 Changes

In an August 2001 directive, OSHA formally adopted many important changes to the OSHA Consultation Program. Among the most important revisions are the following:

•	Employee Participation in General: Employees must be allowed to accompany the employer during the inspection process.

•	Employee Participation at Union Sites: The employee representative must be allowed:

-	to accompany the consultant and employer representative during inspection of the workplace; and

-	to participate in opening and closing conferences with the consultant (jointly with the employer if possible; otherwise, separately).

•	Employee Participation at Non-Union Sites: In the absence of a recognized employee representative, the consultant must meet with a "reasonable number" of employees on health and safety matters.

•	Consultant's Written Report on Initial Visit: This must be prepared by the consultant no later than 20 days after the closing conference.

•	Preparation of List of Hazards: The consultant's written report must include a List of Hazards that:

-	describes the serious dangers; and

-	identifies the mutually determined date by which the hazards will be corrected.

•	Posting of List of Hazards: The employer must post the list, unedited, in a prominent location until the latter of:

-	three working days; or

-	the date on which the hazards are corrected.

•	Protection from Inspection While Correcting Hazards: OSHA will not conduct an inspection while employers correct identified hazards if:

-	the employer is within the correction due dates;

-	interim protection is being used; and

-	the list has been posted as required.

•	Consultation Status: Consultations are considered to be "in progress" (and to take precedence over programmed inspections) from the start of the opening conference until the end of the correction due dates.

•	Criteria for Inspection Exemption (Deferral): Participants in the consultation program may be exempted from programmed inspections for a period of up to 18 months if they:

-	meet the eligibility requirements for OSHA's Safety and Health Recognition Program (SHARP) (see SHARP Participation);

-	correct all hazards identified through the consultation; and

-	appear reasonably likely to meet safety goals in a timely fashion.

•	Monitoring Consultation Programs: OSHA is intending to monitor the efforts of the consultation programs in relation to the agency's strategic and performance goals.

Directory of Consultation Projects

For a directory of OSHA/State Consultation Projects, see OSHA/State Consultation Project Directory.


Control of Hazardous Energy (Lock-Out/Tag-Out)
Control of Hazardous Energy

(Lock-Out/Tag-Out)

When service or maintenance is performed on machines and equipment, it must be done with the machine or equipment stopped. All sources of energy must be disconnected. The energy devices for that machine or equipment must be locked-out or tagged-out under a documented procedure. (Exception: The standard does not apply to servicing or maintaining cord- and plug-connected electrical equipment if the equipment is unplugged from the energy source and remains under the exclusive control of the employee performing the service or maintenance.)

Employees involved in energy control plans must be given training. Periodic inspections of the procedures must be conducted at least annually to ensure the continued effectiveness of the plan. The periodic inspection must include a review of the procedure with all employees when lock-out or tag-out is used.

When outside contractors are performing servicing or maintenance, each employer must coordinate with the other employers to ensure that no employees are endangered. When a group of employees are servicing equipment, each employee must use individual lock-out or tag-out. When servicing or maintenance extends over more than one shift, specific procedures must be used to ensure personnel protection.

Procedures for the orderly transfer of lock-out or tag-out control must be developed. This must be done to reduce the hazard from the unexpected start-up of the machine or equipment.

29 CFR 1910.147

Training requirements for the control of hazardous energy are discussed in Chapter 7, Control of Hazardous Energy (Lock-Out/Tag-Out). A sample Lock-Out/Tag-Out Plan is available from Summers Press in its Sample Safety Plans on CD.


Cranes, Hoists, and Other Lifting Equipment

Inspection and Maintenance

All functional operating mechanisms and lifting equipment must be visually inspected daily.

29 CFR 1910.179(j)

Chains, cables, ropes, hooks, and the like on overhead and gantry cranes must also be looked over daily. Each month a full written, dated, and signed report of the condition of each must be prepared. This report must be kept on file and readily available to appointed personnel. The inspector will look for such things as deformation, cracks, excessive wear, twists, and stretching. Defective gear must be repaired or replaced.

29 CFR 1910.179(j)

Complete inspection of the crane must be performed at 1- to 12-month intervals. The required frequency of inspection depends on the crane's activity, severity of service, and environmental conditions. The inspection will include the following areas:

•	deformed, cracked, corroded, worn, or loose members or parts

•	the brake system

•	limit indicators (wind, load, etc.)

•	power plant and electrical apparatus

Hoist ropes on crawler, locomotive, and truck cranes must be free from twists. The ropes may not be wrapped around the load.

29 CFR 1910.180

All U-bolt wire rope clips on overhead and gantry cranes must be installed so the U-bolt is in contact with the dead end (short or non-load-carrying end) of the rope. Clips must be installed following procedures recommended by the clip manufacturer.

29 CFR 1910.179(v)

All nuts on newly installed clips must be retightened after one hour of use.

29 CFR 1910.179; 29 CFR 1910.180

Safe Operation

Overhead cranes must have stops at the limit of travel of the trolley. Bridge and trolley bumpers or equivalent automatic devices must be provided. Bridge trucks must have rail sweeps.

29 CFR 1910.179(e)

The rated load of the crane must be plainly marked on each side of the crane. If the crane has more than one hoisting unit, each hoist must have its rated load marked on it or on its load block. All marking must be clearly legible from the ground floor.

29 CFR 1910.179(b)(5)


Dip Tanks

Dip tanks include any containers that:

•	hold a liquid other than water; and

•	are used for dipping, coating, or altering the surface or character of an object.

29 CFR 1910.123

Examples of dip tank operations covered by OSHA regulations include paint dipping, electroplating, pickling, quenching, tanning, degreasing, stripping, cleaning, roll coating, flow coating, and curtain coating.

29 CFR 1910.123

Ventilation

The dip tank and surrounding area must be ventilated so that the airborne concentration of any substance is below 25% of its lower flammable limit (LFL).

29 CFR 1910.124

Employers may use either a tank cover or a material that floats on the surface to replace or supplement ventilation as long as the standard's requirements are met.

29 CFR 1910.124(b)(3)

If mechanical ventilation is used, it must:

•	draw the flow of air into a hood or exhaust duct;

•	provide an independent exhaust system for each dip tank (unless there is no possibility of fire, explosion, or chemical reaction); and

•	provide each room having exhaust hoods with a volume of outside air that is at least 90% of the volume of the exhaust air.

29 CFR 1910.124

When the vapor concentration of any substance in the exhaust airstream exceeds 25% of its LFL, there must be a system that sounds an alarm and automatically shuts down the operation.

29 CFR 1910.124(c)(3)

Hygiene Facilities

If employees work with liquids in dip tanks that may burn, irritate, or harm the skin, employers must provide:

•	locker space or storage space to prevent the contamination of the street clothes of the employees;

•	an emergency shower and eye-wash station close to the dipping or coating operation (alternatively, a water hose at least 4 feet long and 3/4 inch thick with a quick-opening valve and pressure of 25 pounds per square inch or less); and

•	at least one basin with a hot-water faucet for every 10 employees who work with such liquids.

Flammable or Combustible Liquids

If dipping or coating operations involve flammable or combustible liquids, all of the following additional requirements apply:

•	Dip tanks must be made of noncombustible materials.

•	A properly trapped overflow pipe that is at least 3 inches in diameter must lead to a safe location outside the building if the dip tank:

-	exceeds 150 gallons in capacity; or

-	has a liquid surface area greater than 10 square feet.

•	All "vapor areas" (any space containing a dip tank and surrounding area with vapor concentration in excess of 25% of the LFL of the liquid in the tank) must be kept:

-	entirely free of combustible debris; and

-	as clear of combustible stock as practicable.

•	An automatic fire-extinguishing system that complies with OSHA fire-suppression standards is required for any dip tank with a capacity of at least 150 gallons or a liquid surface area of at least 4 square feet. Such a system is also required for any hardening and tempering tanks having a liquid surface area of 25 square feet or more, or a capacity of 500 gallons or more.

29 CFR 1910.125

Related Topics

An inspection checklist for dip tanks is included in Chapter 5. Training requirements are in Chapter 7.


Dockboards

Dockboards must be strong enough to carry the load imposed on them.

Portable dockboards must be anchored or equipped with devices that prevent their slipping. They will have hand holds or other effective means to allow safe handling.

Positive means must be used to prevent railroad cars from being moved while dockboards are in position.

29 CFR 1910.30


Drinking Water

Potable water will be provided in all places of employment.

Potable water dispensers will be designed, constructed, and serviced to ensure sanitary conditions. All potable water containers must be capable of being closed, and each must have a tap.

29 CFR 1910.141


Electrical Safety-Related Work Practices

To ensure that employees engage in safe work practices, an employer must make employees aware of the electrical hazards to which they will be exposed.

Employers are required to train employees in safety-related work practices, as well as any other procedures necessary for safety from electrical hazards.

De-energizing electrical equipment prevents the accidental or unexpected starting of electrical equipment that can cause injury or death. Before ANY inspections or repairs are made, power should be turned off at the switch box and the switch should be padlocked in the OFF position. This is true even on so-called low-voltage circuits. Further information on lock-out/tag-out procedures is contained in Control of Hazardous Energy (Lock-Out/Tag-Out), and in the Sample General Safety Plan (refer to the Lock-Out/Tag-Out section).

Maintenance employees should be qualified electricians who have been instructed in lock-out and tag-out procedures. No two locks can be alike. Each key should fit only one lock, and only one key should be issued to each maintenance employee.

If more than one employee is repairing a piece of equipment, each should lock out the switch with his or her own lock. An employee should never unlock another employee's lock nor permit another employee to unlock his or her lock.

The maintenance worker should always be certain that he or she is not exposing other employees to danger.

If work is performed near overhead power lines, the lines must be de-energized and grounded by the owner or operator of the lines. Protective measures (such as guarding or insulating the lines) must be designed to prevent employees from contacting the lines.

Unqualified employees and mechanical equipment must stay at least 10 feet away from overhead power lines. If the voltage is over 50,000 volts, the clearance should be increased by four inches for each 10,000 volts.

When mechanical equipment is being operated near overhead lines, an employee standing on the ground may not contact the equipment.

This prohibition does not apply if the equipment is located so that the required clearance cannot be violated even at the maximum reach of the equipment.

OSHA requires portable ladders to have nonconductive side rails if used by an employee who would be working where he or she might contact exposed energized circuit parts. This should protect the worker from electrical shock.

To increase his or her own safety from electrical hazards an employee should always use tools that work properly. Tools should be inspected before use, and those found questionable removed from service and properly tagged. Tools and other equipment should be regularly maintained.

Inadequate maintenance can cause equipment to deteriorate, resulting in an unsafe condition. Tools to handle energized conductors must be designed to withstand the voltages and stresses to which they are exposed.

29 CFR 1910.332 - 1910.335

Training requirements for electrical power generation and distribution are discussed in Chapter 7, Electric Power Generation and Distribution.


Electrical Utilization Equipment

Splices

Conductors must be spliced or joined with devices suitable for their use or by brazing, welding, or soldering. All splices, joints, and free ends of conductors must be covered with insulation. The insulation must be equivalent to that of the conductor or be an insulating device suitable for the purpose.

29 CFR 1910.303(c)

Marking

Markings on electrical equipment must be provided. The marking must give voltage, wattage, and other ratings, as necessary, with the manufacturer's identification. Each service, feeder, and branch circuit must be legibly marked to show its purpose unless located and arranged so that the purpose is clear. The markings must be at all disconnecting means or over-current devices.

29 CFR 1910.303(e)

Guarding

Live parts of electrical equipment operating at 50 volts or more must be guarded against accidental contact. This can be done by using approved cabinets or other forms of approved enclosures, or by location. Entrances to guarded locations containing exposed live parts must be marked with warning signs.

29 CFR 1910.303(g)(2)

Overcurrent Protection

Conductors and equipment must be protected from overcurrent according to their ability to conduct current safely.

29 CFR 1910.304(e)

Grounding

For a grounded system, both the equipment-grounding conductor and the grounded circuit conductor must be connected to the grounding electrode. Both the equipment-grounding conductor and the grounding electrode conductor must be connected to the grounded circuit conductor on the supply side of the service. The ground system could be at the disconnecting means or overcurrent devices if the system is separately derived.

For an underground service-supplied system, the equipment-grounding conductor must be connected to the grounding electrode conductor at the service equipment.

29 CFR 1910.304(f)

The path to ground from circuits, equipment, and enclosures must be permanent and continuous. Exposed non-current-carrying metal parts of fixed equipment that may become energized must be grounded:

•	if within eight feet vertically or five feet horizontally of the ground or grounded metal objects if subject to employee contact;

•	if located in a wet or damp location and not isolated;

•	if in electrical contact with metal;

•	if in a hazardous location;

•	if supplied by a metal-clad, metal-sheathed, or grounded metal-raceway wiring method; or

•	if equipment operates with any terminal at over 150 volts to ground, with certain exceptions.

Equipment connected by cord and plug must be grounded:

•	if it is in a hazardous location;

•	if it operates at more than 150 volts to ground;

•	if it is used in a damp or wet location; or

•	if it is used by persons:

-	standing on the ground or on metal floors;

-	working inside metal tanks or boilers; or

-	likely to be in wet and conductive locations.

Specific types of cord- and plug-connected equipment are to be grounded. Double-insulated tools supplied by an isolating transformer at not more than 50 volts are exempted.

29 CFR 1910.304(f)(4); 1910.304(f)(5)

Flexible Cords and Cables

Unless specifically permitted, flexible cords and cables may not be used:

•	as a substitute for the fixed wiring of a structure;

•	where attached to building surfaces;

•	where concealed or where run through holes in walls, ceilings, or floors; or

•	where run through doorways, windows, or similar openings.

Flexible cords will be used only in continuous lengths without splice or tap. Hard-service flexible cords No. 12 or larger may be repaired if properly spliced.

29 CFR 1910.305(g)

Flexible cords must be connected to devices and fittings so that strain relief is provided. This must prevent pull from being directly sent to joints or terminal screws.

29 CFR 1910.303 - 1910.305

Electrical Outlet Covers

In completed installations, each outlet box must have a cover, faceplate, or fixture canopy. Outlet box covers with holes for flexible cord pendants must have bushings designed for that purpose or smooth, well-rounded surfaces to bear the cords.

29 CFR 1910.305(b)(2)


Elevators, Dumbwaiters, Escalators, and Moving Walks

Elevators, dumbwaiters, escalators, and moving walks will have a single means for disconnecting all ungrounded main power supply conductors for each unit.

On a multiple car installation system that remains energized from a source other than the disconnecting means, a warning sign must be mounted on or next to the disconnecting means. The sign must be clearly legible and must read "Warning: Parts of the control panel are not de-energized by this switch."

The following are good practice procedures, although they are not included in OSHA standards:

•	All elevators should be inspected annually by a competent inspection service or inspector.

•	All hoist-way openings should be protected by double doors or gates that are interlocked with controls. Controls should prevent the car from starting until all gates or doors are closed. The gates or doors should not open when the car is not at a landing.

29 CFR 1910.306


Emergency Action Plans

Employers must prepare written emergency action plans for employee safety during fires and other emergencies. Employers with 10 or fewer employees, however, may have an oral plan. This plan must be reviewed with affected employees.

The plan must include the following elements:

•	escape procedures and routes

•	procedures for critical plant operations

•	employee accounting following an emergency evacuation

•	rescue and medical duties

•	means of reporting emergencies

•	persons to be contacted for information or clarification

29 CFR 1910.38

A sample Emergency Action Plan is provided in Chapter 3.

Training requirements for alarm systems are discussed in Chapter 7, Alarm Systems. Training requirements for emergency evacuation are discussed in Chapter 7, Emergency Evacuation.


Employee Complaints

Any employee or employee representative may file a complaint and request an inspection for violation of OSHA standards (see Basic Employee Rights). On request, the Department of Labor will maintain the confidentiality of any party who files a complaint.

OSHA has issued an Instruction (CPL 2.115) dealing with complaint policies and procedures. Complaints will be classified as resulting in either:

•	Complaint Inspections: complaints resulting in on-site inspections; or

•	Complaint Investigations: complaints resulting in off-site investigations using telephone, fax, or similar means.

Complaint Inspections

"Complaint inspections" are reserved for complaints that involve the greatest danger to workers and the highest priority. Complaints must involve at least one of the following eight factors for OSHA to conduct an on-site inspection:

•	a written, signed complaint by a current employee or employee representative detailing a violation that threatens physical harm or imminent danger

•	physical harm resulting from a hazard that still exists

•	a report of an imminent danger

•	an establishment or hazard covered by an OSHA emphasis plan

•	failure by the employer to properly respond to an investigation

•	citations by the employer in the last three years for:

-	egregious or willful violations; or

-	failure to abate hazards

•	referral from a whistleblower investigator

•	complaint at a facility scheduled to undergo or currently undergoing an OSHA inspection

Complaint Investigations

In cases involving "complaint investigations," OSHA informs the employer of the alleged hazards over the phone and follows up with a letter or fax. The employer then has five days to respond in writing. The employer's response must identify any problems and planned or completed corrections. Unless the response is inadequate, OSHA generally will not conduct an inspection based on an investigation.

The OSHA Area Director determines which complaints meet the requirements for an on-site inspection and which require only an off-site investigation.

Online Complaints

OSHA has created "The Workers' Page" as part of its Internet site (see OSHA Internet Site). This page informs workers of their rights and obligations under OSHA. In addition, the page enables employees to file complaints online.

OSHA indicates that most online complaints are handled as "complaint investigations." This means that they are less likely to involve an actual on-site inspection than a formal, signed complaint.

No Discrimination Against an Employee Based on a Complaint

Section 11(c)(1) of the Occupational Safety and Health Act prohibits any person from discharging or discriminating against an employee in any way because the employee:

•	has filed a complaint or caused any proceedings to be instituted under the Act;

•	has testified or will testify in any proceeding under the Act; or

•	exercises any right on behalf of himself or herself or others under the Act.

29 U.S.C. § 660(c)


Employee Consultation with OSHA Inspector

During the course of an inspection, each employee must be allowed an opportunity to notify an OSHA inspector of any violation the employee believes exists in the workplace (see Employee Complaints).

An OSHA inspector, formally named a Compliance Safety and Health Officer (CSHO), may consult with employees during an inspection to the extent necessary to conduct an effective and thorough inspection (see Inspection Procedure).

29 CFR 1903.10


Ergonomics, Basics
Ergonomics

Ergonomics is the science of work. It is often said that the purpose of ergonomics is to fit the job to the person, rather than the person to the job. Basically, this means that employers should design jobs with human needs and limitations in mind in order to avoid unnecessary injuries.

Ergonomics is mostly concerned with musculoskeletal disorders (MSDs), which are also known as cumulative trauma disorders (CTDs), repetitive motion injuries (RMIs), and repetitive stress injuries (RSIs). These are injuries to the muscles, nerves, tendons, ligaments, cartilage, and spinal discs caused by employee exposure to certain risk factors (see subsection below). Common MSDs are tendinitis, low back pain, and carpal tunnel syndrome.

OSHA believes that work-related MSDs account for over 33% of the occupational injuries and illnesses that cause lost time from work. In November of 2000, OSHA issued a final ergonomics rule to reduce these injuries and illnesses. However, in March of 2001, Congress voted to repeal OSHA's new standard.

In April of 2002, OSHA released its much anticipated plan to reduce ergonomic injuries. The new plan will rely on voluntary guidelines, rather than mandatory standards, to reduce MSDs. The guidelines are to be industry- and task-specific and will take into account already developed practices and recommendations. OSHA expects to begin releasing the new guidelines for selected industries by the end of 2002.

On the enforcement side, OSHA will continue to use the general duty clause to cite employers that fail to adequately protect their employees from ergonomic hazards. OSHA will focus its efforts on those employers that fail to take good-faith efforts to reduce ergonomic hazards, as well as those that fail to implement effective ergonomic programs. OSHA also will continue to implement its National Emphasis Program for the nursing home industry, especially regarding ergonomic hazards related to patient lifting.

Besides the use of voluntary guidelines and enforcement actions under the general duty clause, OSHA has announced two other prongs of its four-pronged, comprehensive approach. First, the agency will provide outreach assistance to businesses, particularly small businesses, to help them prevent ergonomic injuries in the workplace. Secondly, OSHA intends to encourage more research on ergonomic issues by working in cooperation with the National Institute of Occupational Safety and Health (NIOSH).

Risk Factors

Most experts regard the following as the most important risk factors for MSDs:

•	Force: Physical effort to accomplish a task or motion

•	Repetition: Frequency with which a task is repeated over and over with little change in movement

•	Awkward Postures: Body parts (e.g., limbs, joints) that deviate significantly from the "neutral position" during work

•	Contact Stress: Stresses involving either repeated or continuous contact between sensitive body tissue and a hard or sharp object

•	Segmental Vibration: Vibration that is localized, such as vibration to the hand or arm from powered hand tools

Ergonomics is not limited to factory or industrial settings. In fact, computer keyboards, video display terminals, and everyday lifting are some of the primary sources of MSDs.


Exits

Every building designed for human occupancy must be provided with enough exits to permit the prompt escape of occupants in case of emergency.

There must be at least two exits in hazardous areas. These exits must be remote from each other.

Approaches to and from exits must be unobstructed and always accessible.

All exits must discharge directly to the street or other open space that allows safe access to a public way.

Exit doors serving more than 50 people, or in high hazard areas, must swing in the direction of exit travel.

Exits must be marked by readily visible, suitably illuminated exit signs. Exit signs must be distinctive in color and provide contrast with surroundings. The word "EXIT" must be composed of plainly legible letters not less than six inches high.

Any door, passage, or stairway that is not an exit or a way to an exit, but could be mistaken for an exit, must be identified by a sign reading "NOT AN EXIT."

29 CFR 1910.36; 1910.37


Explosives and Blasting Agents

Storage

Stored packages of explosives must be laid flat with topside up. Black powder, when stored in magazines with other explosives, must be stored separately.

29 CFR 1910.109(c)(1)

All explosives must be kept in approved magazines.

29 CFR 1910.109(c)(5)

Required Clearance

The following are not allowed within 50 feet of magazines:

•	smoking

•	matches

•	spark-producing devices

•	firearms

The magazine areas must be kept clear of all combustible materials for a distance of at least 25 feet. Combustible materials may not be stored within 50 feet of magazines.

29 CFR 1910.109(g)(5)

Training requirements for explosives and blasting agents are discussed in Chapter 7, Explosives and Blasting.


Eye and Face Protection

Employees must use eye or face protection when exposed to flying particles, molten metal, chemical liquids, gases or vapors, or potentially dangerous light radiation. Protective eye and face equipment must be maintained in sanitary condition.

Eye and face protection equipment must comply with ANSI Z87.1-1989: "Practice for Occupational and Educational Eye and Face Protection."

29 CFR 1910.133

A sample plan for selecting personal protective equipment (including eye and face protection) through a required hazard assessment is provided in Chapter 3.


Eye Wash

If the eyes or body could be exposed to corrosive materials, facilities for quick drenching or flushing of the eyes and body must be provided. Facilities must be within the work area for immediate emergency use.

29 CFR 1910.151


Fall Arrest Systems

Personal fall arrest systems must be rigged to prevent an employee from free falling more than six feet or contacting any lower level.

29 CFR 1910.66


Fall Protection

OSHA has detailed regulations for protecting any employee with exposure to falls. Employees are considered exposed to possible falls in a number of different situations.

For example, under general industry standards, employers must provide the following:

•	protection at floor openings

•	protection at wall openings and holes (from which there is a drop of more than four feet)

•	protection at open-sided floors, platforms, and runways (four feet or more above floor or ground level)

•	stairway railings and rails that meet certain specifications

29 CFR 1910.23

Additional general industry standards may also apply, depending on the employee activity and nature of the hazard.

Under construction industry standards, employers must generally provide conventional fall protection (guardrail system, safety net system, or personal fall arrest system) whenever an employee may fall six feet or more from any surface. In addition, specific fall protection regulations apply to a wide variety of different hazards. In certain limited circumstances (residential, precast concrete, or leading edge work), a construction employer may use a fall protection plan instead of conventional fall protection. However, that employer must meet very detailed requirements and show that conventional fall protection is infeasible or more hazardous.

29 CFR 1926.501


Fan Blades

When the blades of a fan are less than seven feet above the floor or working level, the blades must be guarded. The guard's openings cannot exceed 1/2 inch in their least dimension.

29 CFR 1910.212


Fines and Penalties, Adjustments

When an OSHA inspector issues a citation, he or she classifies the violation as serious, other-than-serious, repeated, or willful. Based on the classification and severity of the infraction, the inspector then typically determines a gravity-based penalty or GBP (see Fines and Penalties, Classification and Assessment). An employer that wants to contest a citation, including the amount of the proposed penalty, must follow designated procedures (see Procedure to Contest a Citation).

A gravity-based penalty is usually adjusted (reduced) according to the following factors:

•	size of business (up to 60% reduction)

•	good faith (up to 25% reduction)

•	history of previous violations (10% reduction)

The GBP may be reduced by as much as 95% if the employer receives the maximum allowable adjustment for each factor. A penalty of $5,000 would shrink to only $250 after the maximum adjustment! However, some adjustments are restricted or eliminated for willful, repeated, or especially serious violations.

Size of Business

The maximum reduction that applies to non-willful violations is shown in the table below:

Number of Employees	Maximum Reduction

1 to 25	60%

26 to 100	40%

101 to 250	20%

For willful violations, adjustments based on size are only one-half of those for non-willful violations (e.g., up to a 30% reduction for a business with 1 to 25 employees, 20% for 26 to 100, 10% for 101 to 250). For repeated violations, no adjustment is available for size, although it is considered in the amount of the proposed penalty (see Fines and Penalties, Classification and Assessment).

Good Faith

A reduction of up to 25% applies to non-willful violations if an employer can demonstrate good faith. The only way for an employer to show good faith is through an effective written health and safety program. In exceptional cases, small employers (1 to 25 employees) may receive the 25% reduction, even though the program is unwritten.

Employers receive a reduction of either 25% or 15%, depending on the quality of their health and safety program, as outlined below:

•	Effective Health and Safety Program: To receive the full 25% credit, the employer's written program must have only "incidental deficiencies" and must satisfy all of these elements:

-	management commitment and employee involvement;

-	worksite analysis to identify hazards;

-	hazard prevention and control; and

-	safety and health training.

•	Deficient Health and Safety Program: An employer whose health and safety program has more than mere incidental deficiencies receives a reduction of only 15%. To receive this reduction, the employer still must have an effective program that is capable of being documented.

•	Availability of "Good Faith" Reduction: This adjustment is not available for:

-	violations classified as high severity and greater probability;

-	willful violations; or

-	repeated violations.

History of Previous Violations

A 10% reduction generally is available to employers that have not been cited for any serious, willful, or repeated violations in the previous three years. This adjustment is not available for repeated violations, but it does apply to willful violations (see Fines and Penalties, Classification and Assessment).


Fines and Penalties, Classification and Assessment

The first step in determining the amount of an employer's fine or penalty is identifying the correct classification of the violation:

•	Other-Than-Serious (Up to $7,000 per Violation): The hazard would probably not cause death or serious physical harm.

•	Serious (Up to $7,000 per Violation): The hazard:

-	creates a substantial probability of death or serious harm; and

-	was known or should have been known to the employer.

•	Posting Violations: The violation of any posting regulations may lead to fines of up to $7,000 per violation.

•	Repeated Violations (Up to $70,000 per Violation): The violation is substantially similar to one for which the employer was cited during a previous inspection.

•	Willful Violations ($5,000 to $70,000 per Violation): The violation was committed with an intentional disregard of, or plain indifference to, OSHA requirements. Reckless conduct by an employer, not just deliberate wrongdoing, may lead to a finding of willfulness.

•	Failure to Abate Violation: The failure to abate a violation within the designated period subjects the employer to fines of up to $7,000 per day for each day the violation continues (partial abatement of a hazard may lead to reductions in fines of 25% to 75%).

Gravity-Based Penalties (GBPs)

After classifying the violation, the next step in assessing the penalty (except for a willful violation) is determining its gravity or severity. This is called the gravity-based penalty or GBP. Two factors are considered in determining the appropriate GBP for a violation:

•	"Severity Assessment": How severe is the potential injury or illness that could reasonably be expected to result from the violation?

-	high severity: potentially leading to death, permanent disability, or chronic irreversible conditions (classified as a serious violation)

-	medium severity: potentially leading to hospitalization or a limited period of disability (classified as a serious violation)

-	low severity: potentially leading to only minor supportive treatment, not hospitalization (classified as a serious violation)

-	minimal severity: unlikely to cause death or serious physical harm, but directly related to safety and health (classified as an other-than-serious violation)

•	"Probability Assessment": How likely is it that an injury or illness could result from the alleged violation?

-	greater probability: relatively likely

-	lesser probability: relatively unlikely

Unlike the severity assessment, the probability assessment does not affect the classification of the violation, but does impact the amount of the proposed penalty.

Note that the GBP is the amount owed before adjustment for business size, good faith, or history of violations. These adjustment factors are very important as they can reduce the actual penalty by up to 95%. See Fines and Penalties, Adjustments for a complete discussion of how these adjustment factors are applied.

Unadjusted GBPs for Serious Violations

Before adjustment factors (employer size, good faith, etc.) are applied, the typical range of proposed penalties for a serious violation is $1,500 to $5,000. The highest gravity classification (high severity and greater probability) is normally reserved for extremely serious dangers. GBPs based on the highest gravity classification are not adjusted for good faith (see Fines and Penalties, Adjustments).

The following unadjusted GBPs generally apply to serious violations:

Severity	Probability	Penalty

High	Greater	$5,000

Medium	Greater	$3,500

Low	Greater	$2,500

High	Lesser	$2,500

Medium	Lesser	$2,000

Low	Lesser	$1,500

In unusual circumstances, OSHA may propose a different penalty than those outlined in the table above. For example, the Area Director may propose a GBP of $7,000 if warranted by an especially serious violation.

Unadjusted Penalties (GBPs) for Other-Than-Serious Violations

The unadjusted GBPs for other-than-serious violations are calculated as follows:

Probability	GBP

Greater	$1,000 to $7,000

Lesser	$0

Penalties for Repeated Violations

To calculate the proposed penalty for repeated violations, the following formulas are used:

•	Small Employers (Fewer Than 250 Employees): The gravity-based penalty (GBP) is multiplied by a factor of 2 for the first repeated violation and by a factor of 5 for the second repeated violation (by a factor of up to 10 if the Area Director considers it necessary to achieve a deterrent effect).

•	Large Employers (More Than 250 Employees): The GBP is multiplied by a factor of 5 for the first repeated violation and by a factor of 10 for the second repeated violation.

•	Repeated Other-Than-Serious Violations: For a repeated other-than-serious violation that otherwise would carry no initial penalty, both large and small employers are fined as follows:

-	$200 for the first repetition of that violation;

-	$500 for the second repetition of that violation; and

-	$1,000 for the third repetition of that violation.

Repeated violations are not adjusted for good faith or previous history of violations (see Fines and Penalties, Adjustments).

Penalties for Willful Violations

Willful violations fall into three basic categories: serious, other-than-serious, and regulatory violations:

•	Serious Violations: These are of high, medium, or low gravity, and they result in the following proposed penalties before adjustment for size or history of violations:

-	high gravity: $70,000

-	medium gravity: $55,000

-	low gravity: $40,000

•	Other-Than-Serious Violations: Minimum penalty of $5,000 (after adjustment)

•	Regulatory Violations (e.g., Posting Violations): Minimum penalty of $5,000 (after adjustment)

Penalties for willful violations may be adjusted by as much as 30% based on employer size and by as much as 10% based on history of violations, for a total reduction of 40% (see Fines and Penalties, Adjustments). For example, if the maximum adjustment of 40% was made to a proposed $70,000 penalty, it would be reduced to $42,000.

29 U.S.C. § 666

Contesting Citations

For information on how to contest citations, see Procedure to Contest a Citation. Note that an employer that fails to file a contest within 15 working days of receipt of notice of proposed penalty generally CANNOT contest the citation.


Fines and Penalties, Criminal Offenses

An employer whose willful violation of an OSHA regulation causes the death of an employee may be charged with a criminal offense. If convicted, the employer may be imprisoned for up to six months (one year for a second offense) and fined up to $250,000 ($500,000 for an organization).

These criminal penalties are completely separate from the civil penalties discussed in Fines and Penalties, Classification and Assessment. In addition, criminal offenses are heard by different tribunals and are subject to a much higher standard of proof (see Standard of Proof).

29 U.S.C. § 666


Fire Doors - No OSHA Standard

Fire doors are not completely covered by present OSHA standards. The following are good practice procedures that might be incorporated into future OSHA standards:

•	Fire doors should be properly labeled as such.

•	Fire doors should not be blocked or tied in an open position.

•	Fusible links for fire doors should be located to function properly in case of fire. They should not be painted.

•	Three 3-inch diameter vent holes are required for tin-clad fire doors up to 9 feet in height. (An additional vent hole is required for doors 9 feet to 12 feet 4 inches in height.) The metal covering around the openings must be secured with small nails and the exposed wood thoroughly painted.

•	A closing device should be installed on every fire door except elevator and power-operated dumbwaiter doors equipped with electric contacts or interlocks.


Fire Extinguishers

Each employer must provide portable fire extinguishers for employee use in the workplace. The employer must mount, locate, and identify them so they are readily accessible to employees. The employer must also provide training in the general principles of fire extinguisher use, including the hazards involved with fire fighting.

Portable fire extinguishers must be serviced at least once a year. A record must be kept to show the maintenance or recharge date. The fire extinguisher pressure gauge must be checked monthly, and the reverse side of the service tag should be initialed in the month inspected.

An exemption from the portable fire extinguisher requirement applies where the employer has a written fire safety policy that requires evacuation on sounding of a fire alarm.

29 CFR 1910.157

Training requirements for fire extinguishers are discussed in Chapter 7, Fire Extinguishers.


Fire Safety

OSHA fire safety regulations are discussed in the sample Fire Safety Plan.

Training requirements for fire safety are discussed in Chapter 7, Fire Safety.


First Aid

Each employer must make available medical personnel for advice and consultation on matters of employee health.

When a medical facility for treatment of injured employees is not available "in near proximity" to the workplace, some person or persons there must be trained to offer first aid. OSHA has interpreted the phrase "in near proximity" to mean no more than:

•	a three- to four-minute response time if a life-threatening or permanently disabling illness or injury can be expected; and

•	a 15-minute response time in circumstances where a life-threatening or permanently disabling injury is unlikely.

First Aid Kits

The first aid standard was recently changed. It no longer requires that employers obtain physician approval for their first aid kits. Now, most employers can simply purchase the appropriate commercial first aid kit. However, if unusual workplace circumstances exist, employers should seek professional advice to modify their commercial kits.

The employer must make sure that:

•	the first aid kit is easily accessible and placed in a weatherproof container;

•	there are individually sealed packages for each type of item in the kit; and

•	the kit is checked:

-	before being sent out on each job; and

-	at least weekly on each job to make sure that used items are replaced.

29 CFR 1910.151

Training requirements for first aid are discussed in Medical Services and First Aid.


Flammable Liquids

Flammable liquids must be kept in covered containers or tanks when not actually in use.

The quantity of flammable or combustible liquid that may be located outside of an inside storage room or storage cabinet or in any one fire area of a building may not exceed:

•	25 gallons of Class IA liquid in containers

•	120 gallons of Class IB, IC, II, or III liquid in containers

•	660 gallons of Class IB, IC, II, or III liquid in a single portable tank

29 CFR 1910.106(e)(2)(ii)(b)

Flammable and combustible liquids may be drawn from or transferred into containers within a building only through a closed piping system. Flammable and combustible liquids may be drawn from safety cans, by a device drawing through the top, or by gravity through an approved self-closing valve. Transferring by air pressure is prohibited.

Inside storage rooms for flammable and combustible liquids must:

•	be constructed of fire-resistive materials

•	be liquid-tight where the walls join the floor

•	have approved self-closing fire doors at all openings

•	have at least four-inch sills, ramps, depressed floors, or an open integrated trench that drains to a safe location

•	have a ventilation system that provides at least six air changes per hour

•	have electrical wiring and equipment approved for general use (in areas for storage of Class II and Class III liquids)

•	have electrical wiring and equipment specially approved for use in hazardous locations (in areas for storage of Class I liquids)

29 CFR 1910.106(d)(4)

Outside storage areas must be graded to divert spills away from buildings.

29 CFR 1910.106(d)(6)

Storage areas should be surrounded with curbs or dikes at least six inches high. Storage areas should drain to a safe location. The areas must be protected from tampering or trespassing. Outside storage must be kept free of weeds, debris, and other combustible material not necessary to the storage.

29 CFR 1910.106(d)(6)

Adequate precautions must be taken to prevent the ignition of flammable vapors. Flammable liquids must be kept away from all sources of ignition.

29 CFR 1910.106(e)(6)

Operational areas where flammable liquids with flash points below 100°F (Class I liquids) are used must be ventilated. The ventilation rate must be at least one cubic foot per minute for each square foot of solid floor area.

29 CFR 1910.106(e)(3)

Class I liquids may not be dispensed into containers unless the nozzle and containers are electrically interconnected.

29 CFR 1910.106(e)(6)

Training requirements involving tanks for combustible or flammable liquids are discussed in Chapter 7, Tanks, Open-Surface.


Floor Load Limits

Floors in every structure (or part of the structure) used for business, industrial, or storage purposes must be marked with a plate that shows the maximum safe floor load. The plates must be provided by the owner of the building. They must be secured to the wall or structure and conspicuously placed in each space to which they relate.

If lost, removed, or defaced, the plates must be replaced by the owner or owner's agent.

It is unlawful to place or permit a load greater than that approved by the building official on any floor or roof of a building or other structure.

29 CFR 1910.22


Floor Openings and Open Sides

Every stairway and ladder-way floor opening must be guarded by a standard railing with standard toeboard on all exposed sides except at the entrance. For infrequently used stairways, the guard may consist of a hinged cover and removable standard railings. The entrance to a ladder-way opening should be guarded to prevent a person from walking directly into the opening.

Every hatchway and chute floor opening must be guarded by a hinged floor opening cover. The cover should be equipped with a standard railing that leaves only one exposed side. As an alternative, the cover may be equipped with a removable railing with toeboard on not more than two sides and fixed standard railing with toeboards on all other exposed sides.

Every floor hole into which persons can accidentally walk must be guarded by either a standard railing with standard toeboard on all exposed sides or a floor hole cover that is hinged in place. While the cover is not in place, the floor hole must be attended or must be protected by a removable standard railing.

Every open-sided floor, platform, or runway four feet or more above an adjacent floor or ground level must be guarded by a standard railing with toeboard on all open sides, except where there is an entrance to a ramp, stairway, or fixed ladder. Runways not less than 18 inches wide used exclusively for special purposes may have the railing on one side omitted where required by operating conditions.

Regardless of height, open-sided floors, walkways, platforms, or runways above or adjacent to dangerous equipment must be guarded with a standard railing and toeboard.

29 CFR 1910.23


Foot Protection

All employees must wear protective footwear when working in area where foot injuries may result from:

•	falling or rolling objects;

•	objects piercing the sole; or

•	the exposure of the employee's feet to electrical hazards.

29 CFR 1910.136

A sample plan for selecting personal protective equipment (including foot protection) through a required hazard assessment is provided in the Sample Hazard Assessment Plan.


Forklift Batteries, Changing and Charging

The charging or changing of batteries used to operate a forklift must meet the following OSHA rules:

Acid and Water

When charging batteries, acid must be poured into water; water may not be poured into acid.

Brakes

Trucks must be properly positioned and the brake engaged before attempting to change or charge batteries.

Designated Area

The battery-charging site must be in an area designated for that purpose.

•	Smoking must be prohibited in the charging area.

•	Precautions must be taken to prevent open flames, sparks, or electric arcs in battery-charging areas.

Equipment

The following rules apply to the charging or changing of batteries:

•	A conveyor, overhead hoist, or equivalent material handling equipment must be provided for handling batteries.

•	A carboy tilter or siphon must be provided for handling electrolyte (acid).

•	Tools and other metallic objects must be kept away from the top of uncovered batteries.

Reinstalled Batteries

Reinstalled batteries must be properly positioned and secured in the truck.

Structures

Facilities used for changing or charging batteries must provide:

•	flooring that is safe for flushing and neutralizing spilled electrolyte (acid);

•	fire protection;

•	protection of the charging apparatus from damage by trucks; and

•	adequate ventilation for dispersal of fumes from gassing batteries.

29 CFR 1910.178(g)

Vent Caps

Care must be taken to ensure that vent caps are functioning. The battery (or compartment) covers must be open to dissipate heat.

29 CFR 1910.178(g)


Forklift Operations

The following requirements apply when operating a powered industrial forklift truck:

•	Forklifts must not be driven up to anyone standing in front of a bench or other fixed object.

•	No person may stand or pass under the elevated portion of any forklift, whether loaded or unloaded.

•	Unauthorized personnel are not allowed to ride on a powered industrial forklift. (A safe place to ride must be provided when riding of trucks is authorized.)

•	Arms or legs must not be placed between the uprights of the mast or outside the running lines of the truck.

•	Special precautions apply whenever a powered industrial forklift is left unattended. The operator must:

-	fully lower the load-engaging means;

-	set the controls to neutral;

-	shut off the power;

-	set the brakes; and

-	block the wheels (if the forklift is parked on an incline).

•	A powered industrial forklift is considered unattended if:

-	the operator is 25 feet or more away from the forklift and the forklift remains in the operator's view; or

-	the operator leaves the forklift, and it is not in the operator's view.

•	Forklifts must have sufficient headroom above them.

•	An overhead guard must be used to protect the operator from falling objects, unless operating conditions do not permit doing so.

•	Forklifts must be equipped with a vertical load backrest extension when the type of load presents a hazard to the operator.

•	Brakes and wheel blocks must be set to prevent movement of trucks, trailers, or railroad cars while unloading onto a forklift.

•	Operators must maintain a safe distance from the edges of ramps and platforms.

•	Forklifts may not be used to open or close freight doors.

•	A powered industrial forklift must be taken out of service until it has been restored to a safe operating condition if it:

-	needs repair;

-	is defective; or

-	is unsafe.

•	Employees must use seat belts and other operator restraint systems if they have been provided by the manufacturer for the particular forklift.

29 CFR 1910.178(k) - (p); CPL 2-1.28

Training requirements for forklifts are discussed in Chapter 7, Forklift Operations. A sample Forklift Safety Plan is available from Summers Press in its Sample Safety Plans on CD.


General Duty Clause

Hazardous conditions or practices not covered in a specific OSHA standard may be covered under Section 5 of the Occupational Safety and Health Act. This section has a catchall provision known as the "general duty clause." It requires employers to furnish a workplace free from recognized hazards that could cause death or serious injury to employees.

29 U.S.C. § 654(a)


Hand and Power Tools

Each employer is responsible for the safe condition of tools and equipment used by employees. This includes tools and equipment that may be furnished by employees.

29 CFR 1910.242

All hand tools must be kept in a safe condition. Handles of tools must be kept tight on the tool, and wooden handles must be free of splinters or cracks. Wedges, chisels, and the like must be free of mushroomed heads. Wrenches may not be used when sprung to the point that slippage occurs.

Electric Power-Operated Tools

The frames of portable electrical tools and equipment must be properly grounded. This does not apply to UL-approved double-insulated construction.

Electrical power tools and equipment showing worn, deteriorated, or inadequate insulation or other parts must be removed from service and repaired or replaced.

29 CFR 1910.242; 1910.304


Hand Protection

Employees must use appropriate hand protection whenever the employees' hands are exposed to the following hazards:

•	skin absorption of harmful substances

•	severe cuts or lacerations

•	severe abrasions

•	punctures

•	chemical burns

•	thermal burns

•	harmful temperature extremes

Employers must select appropriate hand protection based on:

•	performance of the hand protection in relation to the tasks to be performed;

•	conditions present;

•	duration of use; and

•	identification of actual and potential hazards.

29 CFR 1910.138

A sample plan for selecting personal protective equipment (including hand protection) through a required hazard assessment is provided in the Sample Hazard Assessment Plan.


Hazard Assessment

Employers must assess the workplace to determine if any actual or potential hazards require the use of personal protective equipment (PPE). OSHA requires employers to first eliminate or reduce hazards through engineering controls and administration (work practice) controls before relying on PPE for hazard protection.

Employers must verify that the required workplace hazard assessment has been performed through a written certification that identifies:

•	the workplace evaluated;

•	the person certifying that the evaluation has been performed;

•	the date of the hazard assessment; and

•	the document as a certification of hazard assessment.

If hazards are present or likely to be present, the employer must:

•	select PPE that is appropriate for each affected employee;

•	inform each affected employee about the PPE selected; and

•	require use of the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment.

29 CFR 1910.132

A sample Hazard Assessment Plan is provided in Chapter 3. Personal protective equipment (PPE) is discussed in the digest topic, Personal Protective Equipment (PPE).


Hazard Communication

The subject of hazard communication is addressed in Chapter 2. Topics include container labeling, Material Safety Data Sheets, and completing an inventory of hazardous chemicals. Training requirements for hazard communication are discussed in the training topic, Hazard Communication. The issue of trade secrets and hazard communication is discussed in Protecting Trade Secrets.

A sample Hazard Communication Plan is located in Chapter 3.


Hazardous Chemicals

See Chapter 2 for labeling, disclosure, and communication requirements regarding hazardous chemicals.


Hazardous Waste Operations

An emergency response plan is required for all potential emergencies involving hazardous substances. This includes plant emergencies involving these substances.

Training is required for all employees who work at hazardous waste cleanup sites or treatment, storage, or disposal facility (TSDF) sites (EPA-permitted sites), and who respond to any emergencies involving hazardous substances. Training requirements for hazardous waste operations are discussed in Chapter 7, Hazardous Waste Operations and Hazardous Waste TSD Facilities.

A safety and health plan with responsibilities and methods for ensuring employee safety is also required. This plan is necessary for employees engaged in hazardous waste cleanup or TSDF activities.

Medical surveillance (physical examination) is required for most hazardous waste, TSDF, and HAZMAT employees. Medical surveillance is used to monitor employees for adverse exposure to harmful substances.

Personal protective equipment must be selected and used to protect employees from hazardous substances and physical hazards.

When necessary, a decontamination procedure must be used to ensure that hazardous substances are removed from workers. This should be done before they leave the worksite. Decontamination procedures should also be used for equipment that is to be taken off-site.

29 CFR 1910.1200


Head Protection

Head protection equipment (helmets) must be worn when there is possible danger of head injuries from impact, flying or falling objects, or electrical shock and burns.

Protective helmets must meet the requirements of ANSI Z89.1-1986 or an equally effective standard.

Helmets for protection against electrical shock and burns must meet the requirements of ANSI Z89.2-1971.

29 CFR 1910.132 - 1910.135; ANSI Z89.1-1986, Z89.2-1971

A sample plan for selecting personal protective equipment (including head protection) through a required hazard assessment is provided in Chapter 3, Sample Hazard Assessment Plan.


Heat Stress

To avoid a citation under the general duty clause (see General Duty Clause), employers must protect workers from the dangers of heat stress. Here are 10 recent tips from OSHA for avoiding the hazards of heat and hot environments:

•	Have workers drink plenty of water (about one cup of cool water every 15 - 20 minutes) and avoid coffee, tea, and other dehydrating drinks.

•	Help workers adjust to the heat by assigning a lighter workload and longer rest periods for the first five to seven days of intense heat.

•	Encourage workers to wear lightweight, loose-fitting, light-colored clothing.

•	Use general ventilation and spot cooling at points of high heat production.

•	Train first aid workers to recognize and treat signs of heat stress.

•	Consider physical fitness in determining the ability of workers to handle hot environments.

•	Provide short, but frequent, rest breaks.

•	Seek medical advice for workers with heart conditions or medication regimens that increase heat-related risks.

•	Monitor temperatures, humidity, and worker responses to the heat at least hourly.

•	Train supervisors to spot symptoms of heat stroke, heat exhaustion, heat cramps, skin rashes, swelling, and other heat-related afflictions.

29 U.S.C. § 654(a)


Hepatitis B Vaccination

Employers must provide hepatitis B virus (HBV) vaccinations at no cost to all employees who might reasonably be expected to be exposed to infectious materials in the performance of their jobs (see Infectious Materials). The vaccination generally must be offered within 10 working days of an employee's initial job assignment, after completion of appropriate training.

Employees who decline the HB vaccine must sign a standard declination form. Eligible employees who decline the vaccine may still request it at a later date. The vaccination must be given by or under the direction of a licensed health care professional. The employer does not have to make the HBV vaccination available to employees who have already received the vaccination series, whose antibody test reveals that they are already immune, or who cannot receive the vaccine for medical reasons.

Examples of employees who must be offered the HBV vaccination are:

•	personnel who administer health care as their primary duty;

•	emergency response personnel, public safety personnel, or any employee expected to render first aid at first aid stations, clinics, or dispensaries; and

•	any employee who might reasonably be expected to be exposed to infectious materials while doing his or her job.

Vaccination After Exposure

In addition, employers must provide HBV vaccinations at no cost for all employees after exposure to infectious materials. The vaccination must be offered as soon as possible after the event (but no later than 24 hours). This includes employees who administer first aid only as a collateral duty to their routine work assignments and who render assistance in any event involving the presence of blood or other potentially infectious materials.

29 CFR 1910.1030

Further Information

The various parts of the bloodborne pathogens regulations are discussed in digest topics, Bloodborne Pathogens and Infectious Materials.

Training requirements for bloodborne pathogens exposure control are discussed in Chapter 7, Bloodborne Pathogens. A sample plan for Bloodborne Pathogens Exposure Control is available from Summers Press in its Sample Safety Plans on CD.


Home Worksites

OSHA has issued an instruction to clarify its policies concerning home-based worksites. To support telecommuting and teleworking, OSHA will not conduct inspections of employees' home offices. Home offices involve the use of office equipment (telephones, computers, fax machines) to perform office work activities at home.

For other home-based worksites (e.g., home manufacturing operations), OSHA will conduct an inspection only if:

•	OSHA receives a complaint indicating that the violation of a safety standard threatens physical harm; or

•	an imminent danger exists (e.g., reports of a work-related fatality).

Examples given by OSHA of potentially hazardous home work include assembling electronics, casting lead jig heads for fishing lures, handling adhesives without proper gloves, and using unguarded crimping machines. The scope of any OSHA inspection concerning hazardous home-based activity will be limited to the employees' work activities.

OSHA CPL 2-0.125


Hooks

Hooks are discussed in Cranes, Hoists, and Other Lifting Equipment.


Housekeeping

All places of employment, passageways, storerooms, and service rooms must be kept clean, orderly, and in a sanitary condition.

29 CFR 1910.22, 1910.141

To aid cleaning, all floors, working places, and passageways must be free from protruding nails, splinters, loose boards, holes, or projections.

29 CFR 1910.22

Floors

All workroom floors must be kept:

•	in a clean condition; and

•	(so far as possible) in a dry condition.

Drainage must be maintained with wet processes. False floors, platforms, mats, or other dry standing places should be provided where practicable.

29 CFR 1910.22(a)(2)


Infectious Materials

The following items are considered infectious materials under the OSHA Bloodborne Pathogens Standard. An employee exposed to any of these items must receive the hepatitis B vaccine, and the employer must comply with the other post-exposure procedures described in the bloodborne pathogens regulations:

•	blood

•	semen

•	vaginal secretions

•	cerebrospinal fluid

•	synovial fluid

•	pleural fluid

•	pericardial fluid

•	peritoneal fluid

•	amniotic fluid

•	saliva in dental procedures

•	any bodily fluid visibly contaminated with blood

•	all bodily fluids in situations where it is difficult to differentiate between bodily fluids, including:

-	any unattached human tissue or organ other than intact skin (from either a living or a dead source),

-	any cells, tissues, or organ cultures infected with or containing the human immunodeficiency virus (HIV),

-	culture mediums or other solutions containing HIV or hepatitis B virus (HBV), or

-	blood, organs, or other tissues from experimental animals infected with HIV or HBV.

29 CFR 1910.1030

The various parts of the bloodborne pathogens regulations are discussed in digest topics, Bloodborne Pathogens and Hepatitis B Vaccination.

Training requirements for bloodborne pathogens exposure control are discussed in Chapter 7, Bloodborne Pathogens. A sample plan for Bloodborne Pathogens Exposure Control is available from Summers Press in its Sample Safety Plans on CD.


Inspections and Investigations

OSHA regulations authorize inspectors (compliance officers) to enter workplaces in order to ensure that employers are complying with safety regulations. Many inspections arise from an OSHA administrative program, such as its Site-Specific Targeting (SST) plan. Other inspections may arise from reports of imminent dangers or from employee complaints. Details on the inspection process, including the pros and cons of demanding a warrant, may be found in Common Triggers for an Inspection and Advance Notice of an OSHA Inspection.

Certain complaints may result in a less formal off-site "investigation," rather than an actual on-site "inspection." For more information on this topic, see Employee Complaints.


Ladders, Fixed

All ladders must be designed to hold at least 200 pounds. All rungs on a fixed ladder must have a minimum diameter of 3/4 inch if metal, or 1 1/8 inches if wood. Rungs must be a minimum of 16 inches wide and should be spaced uniformly no more than 12 inches apart.

Cages, wells, or ladder safety devices for ladders hooked to towers, water tanks, or chimneys must be provided on all ladders over 20 feet long. Landing platforms must be provided for each 30 feet of length. If no cage is provided, landing platforms must be provided for every 20 feet of length.

Tops of cages on fixed ladders must extend 42 inches above the top of the landing, unless another acceptable protection is provided. The bottom of the cage must be not less than seven feet nor more than eight feet above the base of the ladder.

Side rails must extend 3 1/2 feet above the landing.

29 CFR 1910.27


Ladders, Portable

Stepladders must be equipped with a metal spreader or locking device of enough size and strength to hold the front and back sections in the open position.

Ladders must be inspected frequently. Ladders with defects must be withdrawn from service. Ladders removed for repair or destruction must be tagged or marked as "DANGEROUS, DO NOT USE."

Ladders that are not self-supporting must be erected with the base of the ladder a distance from the wall or upper support equal to 1/4 the length of the ladder. Ladders must be placed to prevent slipping.

The top of the ladder used to gain access to a roof should extend at least three feet above the point of contact.

In general industrial use, portable metal ladders may be used in areas containing electrical circuits, if proper safety measures are taken.

29 CFR 1910.25; 1910.26


Lead

Under the OSHA lead standard for general industry, employers must make sure that employees are not exposed above permissible limits. The standard applies to all occupational exposure to lead, except for that involving the construction industry or agricultural operations. "Lead" includes metallic lead, all inorganic lead compounds, and organic lead soaps.

Exposure Assessment

Every employer covered by the lead standard must first determine if any employee without a respirator may be exposed to an airborne concentration of lead at or above the "action level." This is defined as 30 micrograms of lead per cubic meter of air (30µg/m3), calculated as an eight-hour time-weighted average (TWA). In addition to the action level, there is the permissible exposure limit, or PEL. It is defined as 50 micrograms per cubic meter of air (50µg/m3) averaged over an eight-hour period.

Air sampling is required if there is any information, including any employee symptoms or complaints, that could indicate lead exposure. Sampling must be done for a full workday in all suspected areas for each job classification. After taking air samples (making an "exposure assessment"), the employer must do one of the following:

•	If lead levels are beneath the action level, the employer must make a written, negative initial determination (including date of the determination, location of testing, airborne lead levels, and name of each monitored employee).

•	If lead levels exceed the action level, but are beneath the permissible exposure limit or PEL, the employer must repeat monitoring at least every six months until two consecutive measurements (taken at least seven days apart) are below the action level.

•	If lead levels exceed the PEL, the employer must repeat monitoring quarterly until two consecutive measurements (taken at least seven days apart) are beneath the PEL. If measurements are still above the action level, the employer must repeat monitoring at least every six months until measurements are beneath the action levels. (See subsection below for required protective measures for employees with exposure above the PEL.)

Regardless of the results of an exposure determination, each employee must be notified in writing of his or her exposure results.

Required Protective Measures/Written Program

Employers must use engineering controls and work practices to reduce an employee's exposure to lead whenever it exceeds the PEL for more than 30 days per year. If engineering controls and work practices are inadequate to reduce lead to levels beneath the PEL, respiratory protection must also be used. An employer is required to provide an employee with a powered air-purifying respirator (PAPR) instead of a negative pressure respirator if the employee requests one and the PAPR will provide adequate protection.

For employees exposed above the PEL, employers must also institute a written compliance program, provide protective clothing, and implement detailed hygiene and housekeeping practices.

A medical exam and consultation must be made available to employees who may be endangered by lead exposure as follows:

•	before assignment for employees exposed to any area with lead at or above the action level (30µg/100g);

•	at least annually for employees whose blood sample at any time in the previous 12 months revealed a lead level at or above 40µg/100g; and

•	as soon as possible for employees who exhibit symptoms associated with "lead intoxication."

Employers also must notify all employees with blood-lead levels above 40µg/100g that the standard requires temporary medical removal if an employee exceeds designated blood-lead levels. Employers must provide medical removal protection if a periodic blood sampling and follow-up sampling for an employee both establish levels at or above 60µg/100g (or above 50µg/100g based on an average of the last three blood samples or all samples over the last six months, whichever is the longer period).

29 CFR 1910.1025


Light Guards

Lamps for general illumination must be protected from accidental contact or breakage by:

•	elevating the lamp at least seven feet from the normal working surface; or

•	using a suitable fixture or lamp holder with a guard.

29 CFR 1910.305(a)(2)(iii)(F)


Lighting

Lighting is covered by OSHA standards for many specific operations. Adequate illumination should be provided and distributed to all areas. The following are good practice procedures in most working environments:

•	20- to 30-foot candle power for service areas

•	50- to 60-foot candle power for areas where specific tasks are performed


Lock-Out/Tag-Out

This subject is discussed in Control of Hazardous Energy (Lock-Out/Tag-Out).


Lunch Rooms

Employees may not eat food or beverages in rooms with a toilet or in any area exposed to a toxic material.

Lunch areas will have a covered receptacle of corrosion-resistant or disposable material for disposal of food waste. The cover may be omitted when sanitary conditions can be maintained without the use of a cover.

29 CFR 1910.141(g)


Machine Guarding

Machine guarding must be provided to protect employees in the machine area from hazards. Hazards include those at the point of operation, nip points, rotation parts, and flying chips and sparks. The guard may not offer a hazard in itself.

The point-of-operation guarding device must be so designed as to prevent any part of the operator's body from entering the danger zone during the operating cycle.

Special supplemental hand tools must permit handling of material without the operator's placing a hand in the danger zone.

Some of the machines that usually require point-of-operation guarding are:

•	guillotine cutters

•	alligator shears

•	shears

•	milling machines

•	power presses

•	jointers

•	power saws

•	forming rolls and calendars

•	portable power tools

29 CFR 1910.212


Machinery, Fixed

Machines designed for a fixed location must be securely anchored. The anchoring must prevent walking or moving during normal operation.

29 CFR 1910.212


Material Safety Data Sheets

Chemical manufacturers and importers must obtain or develop a Material Safety Data Sheet (MSDS) for each hazardous chemical they produce or import. Employers must have an MSDS for each hazardous chemical in the workplace.

29 CFR 1910.1200(g)

Further information on MSDSs is located in Chapter 2.


Mats, Insulating

Insulating mats or platforms must be provided where:

•	motors or controllers operating at more than 150 volts to ground are guarded against contact only by location; or

•	adjustments or other attendance may be necessary during operations.

29 CFR 1910.305


Mechanical Power Presses

Each employer must provide and ensure use of point-of-operation guards on every operation performed on a mechanical power press. Guards must be properly applied and adjusted. Guards must prevent entry of hands or fingers into the point of operation. Guards must prevent reaching through, over, under, and around the guard on every operation on a mechanical power press. This requirement does not apply when the point-of-operation opening is less than 1/4 inch.

Hand and foot operations must be provided with guards to prevent accidental starting of the press.

Presence-sensing devices may not be used to start a slide motion except when used in total conformance with 29 CFR 1910.217(h), which requires certification of the control system.

All machines using full revolution clutches must have a single-stroke mechanism. This requirement does not apply if the machines are automatically fed in continuous operation and are fully safeguarded by a fixed barrier guard.

A main disconnect switch capable of being locked in the OFF position must be provided with every power-press control system.

The employer must establish a plan of regular inspections of its power presses to maintain safe operating conditions. The employer must maintain a record of inspections and maintenance work.

All point-of-operation injuries must be reported to OSHA or the state agency within 30 days.

29 CFR 1910.217

Training requirements for mechanical power presses are discussed in Chapter 7, Mechanical Power Presses.


Medical Records, Access and Retention

Under OSHA standards, employees and former employees who are exposed to toxic substances or harmful physical agents in the workplace have the right to access their medical and exposure records. OSHA has interpreted the relevant standard quite broadly. Once an employee suffers occupational exposure, he or she has the right to access his or her entire medical record with the employer, including any non-occupational medical documents.

However, several kinds of records are excluded from this access requirement. Employees are not entitled to access:

•	physical specimens (e.g., blood or urine samples) that are routinely discarded in normal medical practice;

•	separately maintained health insurance claim records that cannot be accessed by employee name or other direct personal identifier (e.g., Social Security number); and

•	separately maintained records for employee assistance programs (alcohol, drug abuse, personal counseling, etc.).

Time and Means of Employee Access

Employees and former employees are entitled to access medical records or exposure records within 15 days of any request. If the employer cannot reasonably provide access within that time, it must notify the affected employee of the reason for the delay and the earliest date when access will be given.

Employees have the right to a copy of a requested record at no charge. The employer has two basic choices. It may provide copies to employees at no cost or it may furnish photocopying facilities without charge to employees and their representatives.

OSHA Right of Access

The standard also entitles OSHA to review medical and exposure records to which employees have access. However, to protect privacy interests, the agency's procedures generally require a written access order before the agency obtains employee medical information in a personally identifiable form. The order must come from an Assistant Secretary of Labor, based on the recommendation of the OSHA Medical Records Officer. The employer is required to post a copy of the written access order (not identifying specific employees by direct personal identifier) and accompanying cover letter for at least 15 working days before access is granted.

No order is required if an affected employee specifically consents in writing to allow agency access. In addition, an access order is not necessary for an OSHA staff physician to consult with the employer's physician on an occupational safety or health issue.

29 CFR 1910.1020; 1913.10

Records Retention

Medical records for each employee must be kept for the duration of employment plus 30 years except for the following:

•	separately maintained health insurance claim records;

•	first-aid records (not including medical histories); and

•	medical records for employees who worked for less than one year for the employer (if the records were given to the employee on termination).

29 CFR 1910.1020(d)(1)


Medical Services and First Aid

This subject is discussed in First Aid. Training requirements for medical services and first aid are discussed in Chapter 7, Medical Services and First Aid.


Multi-Employer Worksites

OSHA has issued a compliance directive that clarifies its multi-employer citation policy. While the multi-employer policy is primarily applicable to the construction industry, the directive may affect general industry employers as well. Under the multi-employer policy, an employer is liable for a hazardous condition if it is a "creating, exposing, controlling, or correcting employer." Each of these categories is briefly described below.

Creating Employer

A "creating employer" is an employer that creates a hazardous condition in violation of OSHA standards. Such an employer may be cited even if the only employees exposed to the hazards are employees of other employers at the site.

Exposing Employer

An "exposing employer" is an employer whose employees are exposed to a hazardous condition. Whenever an exposing employer knows (or should reasonably know) about a hazard, it must take the following actions to protect its employees, even if the exposing employer did not create the hazard:

•	If the exposing employer has the authority to correct the hazardous condition, it must do so promptly.

•	If the exposing employer does not have authority to correct the condition, it must do all of the following:

-	notify its employees of the hazard;

-	ask the correcting or controlling employer to correct the hazard; and

-	take reasonable steps to protect its employees (including removal from the job in imminent danger and other extreme circumstances).

Controlling Employer

A "controlling employer" is an employer that has general supervisory authority over the worksite (e.g., a general contractor), including the power to correct health and safety violations or to require others to correct them. Such control can be established through contractual provisions or through actual practices.

A controlling employer must act reasonably to detect and correct violations for the protection of workers at the site. The controlling employer's duty to protect employees of other employers is less than that owed to the controlling employer's own employees. However, it still must be reasonable under the circumstances. The following factors are examined in determining the reasonableness of the controlling employer's actions:

•	the size and scope of the project

•	the pace and nature of the work and related hazards

•	the controlling employer's familiarity with the other employer's work history:

-	more frequent inspections required for employers with a poor or unknown compliance record

-	less frequent inspections required if the other employer has a consistently high level of compliance and an effective, graduated system to correct noncompliance

Correcting Employer

A "correcting employer" acts to detect and correct safety hazards as part of a common undertaking on a worksite. Such an employer will be liable if it fails to exercise reasonable care in preventing and discovering hazardous conditions that constitute an OSHA violation.

Multiple Roles

An employer may be performing multiple roles and may be potentially liable under several different categories. For example, a creating employer will often expose its employees to the created hazard and also qualify as an exposing employer. In addition, a creating, controlling, or exposing employer may qualify as a correcting employer if it acts to correct a hazard.

Validity of the Doctrine

Many general contractors and subcontractors have challenged OSHA's multi-employer doctrine on the ground that it exceeds the statutory authority granted to OSHA. However, the vast majority of courts have upheld the doctrine as being within OSHA's authority if the general contractor:

•	unreasonably failed to correct a hazard that it created; or

•	unreasonably failed to direct a subcontractor to correct a hazard created by the subcontractor.

Only the federal Court of Appeals for the 5th Circuit (which has jurisdiction over Louisiana, Mississippi, and Texas) has ruled that the multi-employer doctrine exceeds OSHA's statutory authority.

29 CFR 1926.16(d); Universal Construction Co., Inc. v. OSHRC, 182 F.3d 726 (10th Cir. 1999)


Musculoskeletal Disorders (MSDs)

Musculoskeletal disorders (MSDs) are injuries to muscles, nerves, tendons, ligaments, cartilage, and spinal discs caused by employee exposure to repetitive motions, awkward postures, and other risk factors. MSDs are also known as cumulative trauma disorders (CTDs), repetitive motion injuries (RMIs), and repetitive stress injuries (RSIs). Common MSDs are tendinitis, low back pain, and carpal tunnel syndrome. Ergonomics, the scientific discipline designed to prevent MSDs, is discussed in the digest topic, Ergonomics.


Noise Exposure

Employer-provided hearing protection must be worn by employees who are exposed to an 8-hour time-weighted average (TWA) above 90 decibels or any other level shown in the table below. If noise levels equal or exceed an 8-hour TWA of 85 decibels, employers must give employees the option of wearing employer-provided hearing protectors.

When noise levels exceed permissible limits, administrative and engineering controls are required to reduce exposures as much as possible. If these controls fail to sufficiently reduce excessive noise levels, hearing protective devices must be used. Employers must afford employees the opportunity to select their protective devices from a variety of suitable choices.

If the sound levels equal or exceed an 8-hour TWA of 85 decibels, employers are also required to implement an effective occupational hearing conservation program (OHCP). Under an OHCP, employers must:

•	properly train employees (see Noise Protection);

•	survey their workplaces at least once every two years for noise hazards;

•	monitor employees and inform them of the results;

•	perform annual audiometric testing on employees;

•	record standard threshold shifts (an average hearing change of 10 decibels or more at 2,000, 3,000, or 4,000 hertz relative to a baseline audiogram); and

•	require employees who have experienced standard threshold shifts to use hearing protective devices.

Permissible Noise Exposures

Safety and Health Standards

Duration Per Day,	Sound Level Decibel (dBA)

Hours	Slow Response

8	90

6	92

4	95

3	97

2	100

1 1/2	102

1	105

1/2	110

1/4 or less	115

29 CFR 1910.95

Training requirements for protection from noise exposure are discussed in Chapter 7, Noise Protection.


Open Pits and Tanks, Covers and Guardrails

Covers and guardrails must be provided to protect employees from the hazards of open pits, tanks, vats, ditches, etc.

29 CFR 1910.22(c)


OSHA Poster

The requirement to post an OSHA-approved poster is discussed in Posting Requirements.


OSHA Survey

OSHA may send an annual survey to an employer as part of its "Data Initiative" (ODI). Employers that are selected to participate in the survey must provide:

•	information on the number of employees and the hours they worked; and

•	information contained in records the employer must keep under OSHA regulations (e.g., the OSHA 300 Log).

The survey report must be returned to OSHA within 30 calendar days or within the time stated in the survey (whichever is later). Small employers and employers in certain SIC classifications that are exempt from keeping injury and illness records are still required to respond to surveys if given advance notice in writing by OSHA. See also Overview of Recordkeeping Requirements in Chapter 4.


Personal Protective Equipment (PPE)

General Requirements

Protective equipment must be used whenever hazards of processes, environmental hazards, chemical hazards, radiological hazards, or mechanical irritants could cause injury or impairment of any part of the body through absorption, inhalation, or physical contact. First, however, an employer must attempt to eliminate or reduce hazards through engineering controls and administrative (work practice) controls.

Personal protective equipment (PPE) includes the following:

•	eye protection

•	face protection

•	head protection

•	extremities protection

•	protective clothing

•	respiratory devices

•	protective shields and barriers

29 CFR 1910.132 - 1910.138

OSHA considers common clothes, such as pants and shirts, to be required PPE under certain circumstances. In a letter of interpretation, OSHA noted that working in shorts or working without a shirt may pose a number of hazards to employees, including skin cancer, burns, and abrasions.

All needed personal protective equipment must be provided, used, and maintained in a sanitary and reliable condition.

The employer is responsible for ensuring the employees wear the designated equipment. When employees provide their own personal protective equipment, the employer must assure its adequacy, including proper maintenance and sanitation of the equipment.

All personal protective equipment must be of safe design and construction for the work to be performed.

29 CFR 1910.132(d)(1)

Training requirements for personal protective equipment are discussed in Chapter 7, Personal Protective Equipment (PPE). A sample plan for selecting personal protective equipment through a required hazard assessment is provided in the Sample Hazard Assessment Plan.


Pneumatic Power Tools

For portable tools, a tool retainer must be installed on each piece of equipment that could eject the tool.

Hose and hose connections for connecting compressed air to equipment must be designed for the pressure and service to which they are subjected.

29 CFR 1910.243(b)


Power Transmission Equipment, Guarding

Guards for mechanical power transmission equipment must be made of metal or other suitable material. Wood guards may be used in woodworking and chemical industries where atmospheric conditions would rapidly deteriorate metal guards, or where temperature extremes make metal guards undesirable.

29 CFR 1910.219(o)

All belts, pulleys, sprockets and chains, flywheels, shafting and shaft projections, gears, couplings, or other rotating or reciprocating parts, or any portion of such, within seven feet of the floor or working platform must be effectively guarded.

All guards for inclined belts must conform to the standards for construction of horizontal belts. All guards must be arranged so that a minimum clearance of seven feet is maintained between the belt and the floor.

Flywheels protruding through a working floor must be guarded.

Guards must extend at least 15 inches above horizontal belts if the belts are seven feet or less from the floor or working surface.

Where gears require a guard, the guard must extend six inches above the mesh point by a band guard covering the face, or the gears must be completely enclosed.

Couplings with bolts, nuts, or set screws extending beyond the flange of the coupling must be guarded by a safety sleeve.

Belts, pulleys, and shafting located in rooms used exclusively for power transmission apparatus need not be guarded when the following requirements are met:

•	The basement, tower, or room occupied by transmission equipment is locked from unauthorized entrance.

•	The vertical clearance in passageways between the floor and power transmission beams, ceiling, or any other objects is not less than 5 feet 6 inches.

•	The intensity of illumination conforms to the requirement of ANSI A11.1-1965 (R1970).

•	The route followed by the oiler is protected in such a manner as to prevent accidents.

29 CFR 1910.219


Pressure Vessels, Portable Unfired

All portable unfired pressure vessels must meet the Standards of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section VIII, 1968.

29 CFR 1910.106(b)(1)(v)

Relief valves on pressure vessels should be set to the safe working pressure of the vessel.

29 CFR 1910.106; 1910.169


Process Safety Management of Highly Hazardous Chemicals

OSHA requires a written safety plan for any of the following chemicals that are used in a "process" (defined as "any activity involving use, storage, handling, or on-site movement of the chemical"):

•	over 100 highly hazardous chemicals at specified quantities that are listed in the OSHA regulations located at 29 CFR 1910.119

•	flammable liquids or gases in quantities of 10,000 pounds or more (except products used solely for heating or fuel)

•	all pyrotechnics and explosives

However, the process safety management standard does not apply to retail facilities, unoccupied remote facilities, or oil or gas well-drilling or servicing operations.

To implement process safety management, a business must establish a written plan that satisfies numerous technical and complex requirements.

29 CFR 1910.119


Radiation

Employers are responsible for protecting any employee from being exposed to more than acceptable limits of radiation. This can be either ionizing or electromagnetic radiation.

Each radiation area must be conspicuously posted with appropriate signs or barriers, or both.

Employers must maintain records of the radiation exposure of all employees for whom personnel monitoring is required.

29 CFR 1910.97; 1910.1096


Railings

A standard railing must consist of top rail, intermediate rail, and posts. Rails must have a vertical height of 42 inches from the upper surface of top rail to floor, platform, or the like.

A railing for open-sided floors, platforms, and runways must have a toeboard whenever falling materials could cause a hazard.

Railings must be capable of withstanding a load of at least 200 pounds in any direction or at any point on the top rail.

A stair railing must be of construction similar to a standard railing. The vertical height may be not more than 34 inches nor less than 30 inches from the upper surface to top rail.

29 CFR 1910.23


Respiratory Protection

Employers must provide and require employees to wear respirators when necessary to protect them from chemical or biological hazards. In general, use of respiratory protection equipment is mandatory when engineering and administrative controls cannot reduce employee exposure to airborne contaminants to acceptable levels, during installation of engineering controls, and in emergencies. Engineering and administrative controls must be used in conjunction with respirators whenever contaminants exceed PELs (permissible exposure limits), even if the controls do not reduce exposure to permissible limits.

Additional requirements may apply to confined spaces and specific contaminants such as asbestos, cotton dust, and regulated carcinogens.

Required Plan

When respirators are required, the employer must institute a written Respiratory Protection Plan. The plan must be administered by a program administrator with sufficient training and experience to do the job properly. In addition, the plan must:

•	have procedures that address the particular hazards and procedures at each worksite;

•	be available for inspection by employees;

•	be regularly checked to determine its effectiveness;

•	be updated to reflect workplace changes that affect respirator use; and

•	contain worksite-specific procedures for all of the following:

-	using respirators properly

-	ensuring that atmosphere-supplying respirators provide enough air

-	fit-testing employees

-	medically evaluating all respirator users

-	cleaning, storing, disinfecting, and inspecting respirators

-	training about respirators and related hazards

-	regularly checking the plan's effectiveness

A sample Respiratory Protection Plan is available from Summers Press in its Sample Safety Plans on CD.

Standard Highlights

The main highlights of the respiratory standard are described below.

•	Hazard Evaluation: Employers must perform a hazard evaluation to identify respiratory hazards and determine appropriate respiratory protection.

•	Reasonably Estimating Employee Exposure: Employers may be able to fulfill their duty to estimate worker exposures in a variety of ways, as long as the method is reasonable under the circumstances:

-	personal monitoring: the most accurate method; OSHA has specific requirements for specific substances (e.g., asbestos and benzene)

-	fixed location monitoring: sampling for short time durations in fixed locations; requires measuring under "worst case" conditions to ensure safety

-	previous studies: trade associations or manufacturers may have data that the employer can apply from previous studies; however, for the employer to generalize from these studies, conditions must be similar to those in the employer's workplace and must represent the highest contaminant exposures that are likely to occur

•	Respirator Selection: The employer must select and provide an appropriate respirator based on:

-	respiratory hazards to which the worker is exposed

-	workplace factors that affect respirator performance and reliability

-	user factors that affect respirator performance and reliability

•	Co-Worker Required for Rescue: In IDLH (immediately dangerous to life and health) atmospheres, employers must ensure that at least one suitably equipped and trained co-worker is outside the IDLH atmosphere to rescue the employee inside if necessary. For interior structural fire fighting, at least two outside rescue workers are required for the two or more fire fighters who enter the structure.

•	Mandatory Medical Evaluation: Before any employee uses a required respirator, a physician or licensed health care professional (PLHCP) under state law must perform an evaluation by using a medical questionnaire (Appendix C to 29 CFR 1910.134) or performing an initial medical exam. To protect the employee's right to confidentiality, the employer is prohibited from seeing any of the employee's answers to the questionnaire or any medical exam records.

•	Fit Testing: Employers must comply with the following rules:

-	Before an employee uses a respirator with a negative or positive pressure tight-fitting facepiece, the employee must be fit tested with the same model and size respirator.

-	Fit tests must be performed at least annually after the initial test and whenever circumstances (e.g., a change in workplace or employee conditions) make a new fit test necessary.

-	An employer may use quantitative fit testing (QNFT) or qualitative fit testing (QLFT); however, only QNFT is allowed for negative pressure air-purifying respirators in an atmosphere that is 10 times or greater than the permissible exposure limits (PELs).

•	User Seal Test: Each time a respirator is worn, employees must also conduct a "user seal test" to verify a proper seal (mandatory Appendix B-1 to 29 CFR 1910.134).

•	Filter Change for Air-Purifying Respirators: The new respirator standard prohibits the use of warning properties (i.e., odors and irritation) as the only basis for determining change schedules. Now, all employers must use either an end-of-service-life indicator (ESLI) or a change schedule to ensure that cartridges and canisters are changed in time. However, employees still must be trained that abnormal odor or irritation is a possible indication that a respirator cartridge needs replacement.

•	Air-Supply Quality for Air-Supplying Respirators: At a minimum, compressed breathing air must meet the requirements for Grade D breathing air.

•	Assigned Protection Factor (APF): The APF is the maximum level of a particular hazard that a respirator can safely handle in relation to the permissible exposure limit (PEL) for the hazard. For example, a half-face, air-purifying, negative-pressure respirator typically has an APF of 10. The respirator can be expected to safely protect the wearer 95% of the time in an atmosphere with a hazardous concentration of up to 10 times the PEL. OSHA reserved sections of the Respiratory Standard that was adopted in 1998 to develop its own APFs. However, the agency still has not done so. For now, employers must use APFs from either the National Institute for Occupational Safety and Health (NIOSH) or the American National Standards Institute (ANSI).

•	Carbon Monoxide Alarms for Air-Supplying Respirators:

-	Air compressors with oil lubrication must have a carbon monoxide alarm or high temperature alarm.

-	Air compressors without oil lubrication do not need to have an alarm, but the employer must ensure that carbon monoxide levels in the breathing air do not exceed 10 parts per million (ppm).

•	Respirator Cleaning and Disinfection: Respirators must be cleaned and disinfected as follows:

-	Respirators for the exclusive use of an individual employee must be cleaned and disinfected as often as needed to be kept clean and sanitary.

-	Respirators used by more than one employee must be cleaned and disinfected before being used by different individuals.

-	Respirators used in emergencies, testing, and training exercises must be cleaned and disinfected after each use and inspected at least monthly.

•	Prohibitions: The use of a tight-fitting respirator is prohibited if a beard, facial scarring, or other condition of the user prevents an effective seal.

•	NIOSH Certification: Employers must select a NIOSH-certified respirator and use it as specified in its certification.

•	Medical Evaluation Records: Employers must retain medical evaluation records as required by OSHA's Access to Employee Exposure and Medical Records Rule (the duration of employment plus 30 years).

•	Fit-Test Records: Fit-test records must be retained until the next fit test.

•	Respirator Training: Training requirements for respirators are discussed in Chapter 7, Respiratory Protection.

29 CFR 1910.134

Letter of Interpretation Regarding Diisocyanates

OSHA has issued a letter of interpretation on the possible use of air-purifying respirators (APRs) for the common diisocyanates. These chemicals, widely used in the manufacture of polyurethane foam as well as certain varnishes and paints, have poor odor warning properties. They include Toulene-2,4-diisocyanate (TDI), Hexamethylene-1,6-diisocyanate (HDI), and Methylene biphenyl isocyanate (MDI).

OSHA stated that an employer could use an APR for protection from the common diisocyanates in limited circumstances. In doing so, OSHA made several important points:

•	Cartridge or Canister Use: The employer must:

-	select a cartridge or canister recommended by the manufacturer for the particular chemical; and

-	implement a change schedule based on objective information or data (unless an end-of-service-life indicator is available).

•	Respirator Selection and Contaminant Concentration: The employer must make sure that the respirator can protect the employee from ceiling limits of the chemical that may develop during routine operations and reasonably foreseeable emergencies.

•	Selection of Alternative Respirators: If an APR is inadequate to protect the employee from diisocyanate hazards, employers need to select a powered air-purifying respirator (PAPR) or supplied-air respirator (SAR).

•	Greater Leakage Risks with Negative Pressure Respirators: Negative pressure respirators are more likely to leak and let in contaminated air if the face-to-facepiece seal fails than are positive pressure respirators.

•	Dangers to Eyes from Vapors: Diisocyanate vapors are corrosive and severely damaging to the eyes. If the employer selects a half-masked respirator, appropriate eye and face protection are also required.

•	Monitoring Employees: If employees using an APR report any problems or symptoms that could be the result of diisocyanate exposure, employers must promptly monitor the employees and take protective action.


Revolving Drums

Revolving drums, barrels, or containers must be guarded. The guard must prevent the drum or container from revolving unless the guard is in place.

29 CFR 1910.212(a)(4)


Ropes

Ropes are discussed in Cranes, Hoists, and Other Lifting Equipment.


Saws, Band

All portions of the band saw blades must be enclosed or guarded except the working portion of the blade.

Band saw wheels must be fully encased. The outside periphery of the enclosure must be solid, wire-mesh, or perforated metal.

29 CFR 1910.213(i)


Saws, Portable Circular

All portable circular saws having a blade diameter greater than two inches must be equipped with guards. Guards must be above and below the base plate or shoe. The upper and lower guards must cover the saw to the depth of the teeth. When the tool is withdrawn from the work, the lower guard must automatically return to the covering position.

This provision does not apply to circular saws used in the meat industry for cutting meat.

29 CFR 1910.243(a)(1)


Saws, Radial

Radial saws must have an upper guard that completely encloses the upper half of the saw blade. The sides of the lower exposed portion of the blade must be guarded. This guard must automatically adjust to the thickness of the material being cut.

Radial saws used for ripping must have non-kickback fingers or dogs.

An adjustable stop must be provided to prevent the forward travel of the blade beyond the position necessary to complete the cut in repetitive operations.

Radial saws must be installed so that the cutting head will return to the starting position when released by the operator.

Ripping and ploughing must be done against the direction that the saw turns.

29 CFR 1910.213(h)


Saws, Swing or Sliding Cut-Off

All swing or sliding cut-off saws must be provided with a hood that encloses the upper half of the saw.

Limit stops must be provided to prevent swing or sliding cut-off saws from extending beyond the front or back edges of the table.

Each swing or sliding cut-off saw must be provided with an effective device to return the saw automatically to the back of the table when released at any point of its travel.

Inverted swing or sliding cut-off saws must be provided with a hood that will cover the part of the saw that protrudes above the top of the table or material being cut.

29 CFR 1910.213(g)


Saws, Table

Circular table saws must have a hood over the portion of the saw above the table. The hood must automatically adjust to the thickness of, and remain in contact with, the material being cut.

Circular table saws must have a spreader aligned with the blade. The spreader must be spaced no more than 1/2 inch behind the largest blade mounted in the saw. Providing a spreader while grooving, dadoing, or rabbeting is not required.

Circular ripsaws must have non-kickback fingers or dogs.

Feed rolls and blades of self-feed circular saws must be protected by a hood or guard. This is to prevent the operator's hands from coming into contact with the in-running rolls.

29 CFR 1910.213(c) - (e)


Scaffolds

General Requirements

Scaffolds must be used when the work cannot be done safely from the ground or other solid structure. The scaffold must be able to support at least four times its maximum intended load and must not be loaded in excess of the intended load. Scaffolds must be maintained in safe condition and repaired immediately.

Specific Requirements

All planking must be scaffold grade, as recognized by grading rules of the species of wood used. The medium permissible spans for 2 x 9-inch or wider planks are shown in the following table:

Materials:	Full Thickness	Nominal

Undressed	Thickness

Lumber	Lumber

Working Load (psf)	25	50	75	25	50

Permissible Span (ft)	10	8	6	8	9

The maximum permissible span for 1 1/4 x 9-inch or wider planks of full thickness is four feet. The medium loading is 50 pounds per square foot.

Scaffold planks must extend over their end supports not less than 6 inches nor more than 18 inches.

Scaffold planking must be overlapped a minimum of 12 inches or secured from movement.

29 CFR 1910.28

Guardrails

Guardrails at least 2 x 4 inches or the equivalent must be installed on all open sides on scaffolds more than 10 feet above the ground or floor. The guardrails must be at least 36 inches and no more than 42 inches high. Toeboards must also be installed on all open sides and must be a minimum of four inches in height. A mid-rail, when required, must be 1 x 4-inch lumber or equivalent.

29 CFR 1910.28(b)(15)


Self-Audits

To comply with the myriad of health and safety regulations, many employers regularly audit or inspect their workplaces and make a written record of their findings. In fact, more than 85% of employers that responded to a recent OSHA survey reported conducting voluntary self-audits of safety and health conditions in their workplaces. Although regular self-audits lead to better safety practices, self-audits also have a possible downside. Many employers fear that written records of self-audits may be used by OSHA to establish safety violations.

In response to these concerns, OSHA has issued a final policy on the use of voluntary self-audits to assess workplace health and safety conditions. The self-audit policy applies to the following groups:

•	Qualifying Class: OSHA has broadened the class of persons who can perform a qualifying self-audit. The class is not limited to safety and health professionals, but includes employees and managers who are competent to identify workplace safety or health concerns.

•	Third Parties: An audit conducted by a third party on the employer's behalf clearly is covered under OSHA's policy.

To qualify under OSHA's adopted policy, a self-audit must be systematic, documented, and objective. The audit need not be comprehensive. It can relate merely to a particular process or hazard as long as it is systematic. However, impromptu observations and communications in the ordinary course of business will not qualify under the audit policy.

Treatment of Self-Audits

Under the terms of the final policy statement, OSHA will treat voluntary self-audits as follows:

•	No "Routine Request": OSHA has stated that it will not "routinely" request such self-audit reports when initiating an inspection and does not intend to use such reports as a means of focusing an inspection. (Note: In response to the original proposal, several commentators expressed concern that the words "not routinely" gave OSHA too much discretion and requested the agency to replace this vague phrase with specific exceptions. However, OSHA refused to do so, on the grounds that it would compromise its enforcement efforts.)

•	Limited Intended Uses: OSHA intends to seek self-audit reports only when the agency has an independent basis to believe that a specific safety or health hazard warrants investigation. Examples of such situations are the occurrence of a fatal or catastrophic accident or a reasonable belief that a hazardous, noncomplying condition exists.

•	No Citation for Corrected Violations: OSHA has stated that it will not issue citations for violations discovered during a qualifying self-audit if:

-	the violations are corrected before initiation of an inspection (or accident, injury, etc., that triggers the inspection); and

-	the employer has taken the necessary steps to prevent a recurrence.

(Note: This "no citation" policy applies even if the violation exists within the six-month period during which OSHA may issue citations.)

•	Evidence of "Good Faith": OSHA may consider a self-audit as evidence of good faith that entitles the employer to a penalty reduction of up to 25% (see Fines and Penalties, Adjustments) if the employer:

-	discovers a violation through a self-audit; but

-	has not yet completed abating the hazard.

•	No Evidence of "Willfulness": OSHA will not treat self-audit reports as evidence of a willful violation if the employer:

-	responds promptly to correct any hazard; and

-	takes necessary steps to prevent future violations.


SHARP Participation

Small employers (i.e., those with fewer than 250 employees at one site or 500 employees company-wide) in high-hazard industries may participate in OSHA's Safety and Health Achievement Recognition Program (SHARP). SHARP is administered through each state's consultative services, which are independent of OSHA's enforcement arm (see Consultative Services). The program rewards participating employers that operate excellent safety and health programs through recognition and deferral (exemption) from inspection by OSHA for a period of up to 18 months.

Eligibility

To be eligible for participation in SHARP, a small employer must:

•	be in an industry on OSHA's high-hazard list or a supplemental high-hazard list;

•	have a single, fixed worksite (if multiple worksites are under common control, they must be evaluated individually);

•	have at least a one-year operating history;

•	have both of the following rates below the industry average:

-	Lost Work Day Injury and Illness (LWDII) rate; and

-	Total Recordable Case Rate (TRCR);

•	have a safety management system containing the major elements under OSHA's 1989 Safety and Health Management Guidelines;

•	score at least 2 on 50 basic attributes on OSHA Form 33; and

•	receive a comprehensive evaluation through OSHA's consultative services in order to detect hazards and to create a safer workplace.

Employer Responsibilities

Before receiving an inspection exemption of up to 18 months, an employer must comply with all of the following obligations:

•	requesting and completing a comprehensive evaluation through the OSHA consultation program (see Consultative Services), including:

-	posting the List of Hazards

-	informing employees about the list

-	correcting all hazards identified through the consultation

-	implementing the consultant's plan for achieving SHARP status

•	posting a letter from the OSHA Regional Administrator granting the inspection exemption

•	notifying recognized employee representatives (at sites with unionized workers) and involving the representatives in the SHARP process

•	agreeing to a full-service comprehensive visit at the end of the exemption period

•	agreeing to notify the Consultation Project Manager before making any changes that would increase hazards in the workplace


Sign Design

All signs must have rounded or blunt corners and be free from sharp edges, burrs, splinters, or other sharp projections. The ends or heads of bolts or other fastening devices must be located so that they are not hazardous.

29 CFR 1910.145(d)


Site-Specific Targeting (SST) Plan

OSHA issued a new directive in April of 2002 that updates its Site-Specific Targeting (SST) plan. Basically, the SST plan uses data gathered from approximately 80,000 employers included in OSHA's Data Initiative or ODI (see OSHA Survey) to focus its investigations on general industry employers with the worst injury records.

The frequency of injuries is measured in terms of Lost Work Day Injury and Illness (LWDII) rates or Days Away, Restricted, or Transferred (DART) rate. The DART rate will eventually replace the LWDII rate. In 2000, the national average LWDII rate for private industry was 3.0. All establishments with LWDII rates at or above 14.0 are placed on a primary list and will be inspected. In addition, establishments with an LWDII rate that is above 8.0, but less than 14.0, are placed on a supplemental inspection list. Establishments on the supplemental list are to be inspected if time allows after completing the primary list.

CPL 2 (SST-02)


Spray Finishing Operations

In conventional dry-type spray booths, over-spray dry filters or filter rolls must conform to the following:

•	The spraying operations must have an average air velocity of at least 100 linear feet per minute.

•	Electrostatic spraying operations must be conducted with an air velocity of at least 60 linear feet per minute.

•	Visible gauges, audible alarms, or pressure-activated devices must be installed to show that the required air velocity is maintained.

•	Filter pads must be inspected after each period of use. Clogged filter pads must be discarded and replaced.

Spray booths must be so installed that all portions are readily accessible for cleaning.

A clear space of not less than three feet on all sides must be kept from storage or combustible construction.

Space within the spray booth on the downstream and upstream sides of filters must be protected with approved automatic sprinklers.

There may be no open-flame or spark-producing equipment within 20 feet of any spraying area, unless separated from the spraying area by a partition.

Electrical wiring and equipment not subject to deposits of combustible residues must be explosion-proof.

The quantity of flammable or combustible liquids kept near the spraying operations may not exceed the supply for one day or one shift.

Bulk storage of portable containers of flammable or combustible liquids must be in a separately constructed building that is detached from other important buildings.

If flammable or combustible liquids are transferred from one container to another, both containers must be grounded. This is to prevent discharge of sparks or static electricity.

All spraying areas must be kept as free from the accumulation of deposits of combustible residues as practical. Cleaning must be conducted daily if necessary. Scrapers, spuds, or other such tools used for cleaning must be of non-spark material.

Residue or scrapings contaminated with residue must be immediately removed from the premises.

"NO SMOKING" signs in large letters on a contrasting-color background must be conspicuously posted in all spraying areas and paint-storage rooms.

29 CFR 1910.107


Stairs, Fixed Industrial

Every flight of stairs having four or more risers must be provided with a standard railing on all open sides. Handrails must be provided on at least one side of closed stairways.

Stairs must be constructed so the rise height and tread width are uniform throughout.

Fixed stairways must have a minimum width of 22 inches.

Fixed stairways must be provided for access from one structure to another for operations that require regular travel between levels.

Fixed stairways must be provided for access to operating platforms and any equipment that requires attention during operations. Fixed stairs must also be provided where access to elevations occurs daily.

Fixed stairways must be provided if the carrying of tools or equipment by hand is normally required.

Spiral stairways are not permitted.

29 CFR 1910.23; 1910.24


Storage

All materials stored in tiers must be stacked, blocked, and interlocked. The height must be limited so that the materials will not slide or collapse.

Storage areas must be kept free from accumulation of materials that are hazards. Hazards include items likely to cause tripping, fire, explosion, or pest harborage. Vegetation control will be exercised when necessary.

If mechanical handling equipment is used, enough safe clearance must be allowed for aisles. This includes loading docks, through doorways, and wherever turns or passage must be made.

29 CFR 1910.176


Tags - Color Coding

Although there is not a formal regulation concerning the colors to be used for accident prevention tags, OSHA recommends the following color scheme:

•	"DANGER"

Red, or predominantly red, with lettering or symbols in a contrasting color.

•	"CAUTION"

Yellow, or predominantly yellow, with lettering or symbols in a contrasting color.

•	"WARNING"

Orange, or predominantly orange, with lettering or symbols in a contrasting color.

•	"BIOLOGICAL HAZARD"

Fluorescent orange or orange-red, or predominantly so, with lettering or symbols in a contrasting color.

•	"SAFETY INSTRUCTION"

The standard background color is white with a green panel with white letters. Any letters used against the white background must be black.

29 CFR 1910.145


Tanks, Open-Surface

Ventilation must be used to reduce the concentration of the contaminant so that no hazard to employees exists.

29 CFR 1910.94

Whenever there is a danger of splashing, employees must wear either tight-fitting chemical goggles or an effective face-shield.

There must be a supply of clean cold water near each tank containing liquid that may be harmful to the skin if splashed on the worker's body. The water pipe must be provided with a quick-opening valve and at least 48 inches of hose not smaller than 3/4 an inch. Alternatively, deluge shower and eye flushes may be provided.

All employees working in and around open-surface tank operations must be instructed about the hazards of their respective jobs and applicable personal protection and first aid procedures relating to those hazards.

29 CFR 1910.94

Training requirements for open-surface tanks are discussed in Chapter 7, Tanks, Open-Surface.


Toeboards

Railings protecting floor openings, platforms, scaffolds, and the like must be equipped with toeboards if falling material could cause a hazard.

A standard toeboard must be at least four inches in height. Toeboards can be either solid or open. If open, the openings may not exceed one inch.

29 CFR 1910.23(e)(4)


Toilets

Every place of employment must be provided with adequate toilet facilities that are separate for each sex. Water closets (stalls) must be provided according to the following:

Number of Persons	Number of Toilet Facilities

(Water Closets)

1 - 15	one

16 - 35	two

36 - 55	three

56 - 80	four

81 - 110	five

111 - 150	six

over 150	one for each additional 40 persons

Where toilet facilities will not be used by women, urinals may be provided instead of water closets, if the number of water closets is not reduced to less than 2/3 of the minimum number specified above.

Separate toilet rooms for each sex need not be provided if a room:

•	will be occupied by no more than one person at a time;

•	can be locked from the inside; and

•	contains at least one water closet.

Each water closet must occupy a separate compartment with a door and walls or partitions between fixtures sufficiently high to ensure privacy.

The above requirements do not apply to mobile crews or normally unattended locations. Employees working at these locations must have transportation available to nearby toilet facilities.

29 CFR 1910.141

Under a recent OSHA memorandum, employers are explicitly required to allow employees necessary access to required bathroom facilities. Employers may not impose unreasonable restrictions on employee use of the facilities.


Trash

All sweepings, solid or liquid wastes, refuse, and garbage must be removed as often as necessary to maintain good sanitary conditions.

29 CFR 1910.141


Ultraviolet (UV) Radiation

Ultraviolet (UV) radiation consists of invisible electromagnetic waves from the sun. These waves can cause sunburn, premature wrinkling, eye damage, and skin cancer. Although the rate of most types of cancer is declining, the rate of skin cancer has skyrocketed. This year, almost one million Americans will develop some form of the disease, and nearly 10,000 will die. Those with fair skin or with many moles (especially irregular or large ones) are especially at risk.

OSHA does not have a specific regulation that addresses the hazards of UV radiation. However, under OSHA's general duty clause, employers must protect employees from recognized hazards that can cause death or serious injury (see General Duty Clause). UV radiation is an especially serious hazard for employees in the construction industry, who often work outdoors.

Construction industry employees should follow these important steps to protect themselves while exposed to UV radiation:

•	Cover Up with Protective Clothing:

-	Wear clothing to shield as much skin as possible. Fabrics differ in their protective qualities. Tightly woven fabrics are best.

-	To test a fabric, an employee should place his or her hand between it and a light source. If the hand is visible, the garment offers little protection.

•	Use a Broad-Spectrum Sunscreen with an SPF of 15 or higher:

-	The SPF (sun protection factor) indicates the sunscreen's protective "multiplier." An SPF of 15 means the employee can stay in the sun 15 times longer without burning; an SPF of 30 indicates the employee can stay out 30 times longer, etc.

-	UV radiation has two types: UVA and UVB. Sunburn is caused mainly by exposure to UVB, but UVA is also dangerous. A sunscreen with the "broad spectrum" label protects against both types.

•	Wear a Wide-Brimmed Hat: This will protect the neck, ears, eyes, forehead, nose, and scalp. A baseball cap helps to shield the front and top of the head, but does not protect the back of the neck or ears where skin cancers commonly develop.

•	Wear Appropriate Sunglasses: The label on protective sunglasses should indicate that they block 99 to 100 percent of UVA and UVB radiation. Darker glasses are not necessarily the best. UV protection comes from an invisible chemical on the lenses, not from their color or darkness.

•	Limit Direct Sun Exposure: UV rays are most intense and dangerous when the sun is highest in the sky, between 10 a.m. and 4 p.m. Seek shade and minimize sun exposure during this period.

Seek Early Treatment

In addition, employees should seek prompt medical attention for any spot on the skin that changes in shape, size, or color or for a sore that does not heal. Skin cancers that are detected and treated early can almost always be cured. Delay in seeking treatment, especially with the most dangerous type of skin cancer (melanoma), can be fatal. Melanoma often starts as a small mole-like growth and will spread to the lungs, brain, and other critical organs if left untreated.


Video Display Terminals (VDTs)

With the rise in use of computers, video display terminals (VDTs) have become a common fixture at many workplaces. Many experts believe that improperly designed and arranged VDTs can cause a variety of repetitive stress injuries. To avoid these injuries and possible citations under the general duty clause, employers need to make sure that their VDTs are ergonomically correct (see Ergonomics).

Chapter 5 contains extensive checklists on both VDTs and Ergonomics.


Voluntary Protection Program (VPP)

Employers that have a strong commitment to safety and excellent safety records may participate in OSHA's Voluntary Protection Program (VPP). The VPP is the centerpiece of OSHA's "new, friendlier" approach to safety compliance. In the VPP, OSHA uses cooperation between management, labor, and government (rather than the issuance of citations and collection of penalties) as the primary method for ensuring a safe workplace. While in the VPP, the employer is removed from OSHA's programmed inspection list. However, OSHA will continue to investigate valid employee complaints, fatalities, catastrophes, and other significant events at participating worksites.

Besides removal from OSHA's programmed inspection list, employers reap other benefits from VPP participation. VPP sites generally experience at least 50% fewer lost workday injuries than the "average" site in a comparable SIC classification. VPP sites are also more profitable. Fewer injuries mean lower workers' compensation costs and greater productivity, as well as public recognition for an employer's commitment to worker safety.

OSHA also benefits from the VPP. The agency is able to focus its limited resources on those employers with the poorest safety records and attitudes.

Requirements for VPP Participation

The exact requirements for VPP participation vary depending on whether an employer wishes to participate in the "merit program" or the "star program." The merit program is for employers that wish to join the VPP and attain star status, but whose safety and health program does not yet fully qualify. The star program is for worksites that are fully self-sufficient in their ability to control hazards.

To participate in the VPP, employers must file a written application to OSHA. Applicants for either the star or merit program must meet each of the following conditions:

•	No Open Citations or Investigations: Applicants must have no open investigations and no pending or open contested notices under appeal.

•	No Willful Violations: During the previous 36 months, the employer must have no affirmed willful violations.

•	Signed Assurances: Employers must promise that they will comply with OSHA regulations and timely correct all hazards.

•	Demonstrated Employee Support for VPP: At unionized sites, support must be offered from the authorized representative for each collective bargaining unit.

•	Initial Inspection and Annual Evaluation by OSHA: The agency must verify the effectiveness of the safety and health program and follow up with an annual program evaluation (as well as an on-site evaluation every three years.)

•	Informed Employees: The employer must explain the VPP to employees and ensure that they have access to results of accident investigations, self-inspections, etc.

Further Information

An interested employer may obtain an information kit from the VPP coordinator in the nearest OSHA regional office (see OSHA Regional and Area Offices) or from OSHA's Division of Voluntary Programs at 202-693-2213. A self-assessment checklist is included in the information kit. The checklist helps an employer to determine if its program meets VPP criteria. The self-assessment checklist and additional information on OSHA's VPP may also be obtained from the agency's Internet site at www.osha.gov/oshprogs/vpp/.


Washing Facilities

Adequate washing facilities must be provided in every place of employment.

Mobile crews or employees at normally unattended work locations must have ready access to nearby facilities.

All facilities must be maintained in a sanitary condition.

A suitable cleansing agent, individual hand towels (cloth or paper), warm air blowers, or clean continuous cloth toweling must be provided.

29 CFR 1910.141


Welding

Welding equipment must be chosen for safe application to the work. Employees who operate welding equipment must be properly trained and qualified.

Mechanical ventilation must be provided when welding or cutting:

•	if there is less than 10,000 cubic feet of air per welder; or

•	if the overhead height is less than 16 feet.

Proper shielding and eye protection for welding hazards must be provided. The welder must be enclosed in a booth or non-combustible screening. The screening must be finished with a material having low reflectivity to visible and ultraviolet radiation.

Proper precautions for fire prevention must be taken in areas where welding or other "hot work" is being done.

Work and electrode lead cables must be frequently inspected. Cables with damaged insulation or exposed bare conductors must be replaced.

Refer to 29 CFR 1910.252(c)(5) - 1910.252(c)(10) for special considerations for welding operations that require the following:

•	fluxes

•	lead

•	coverings

•	beryllium

•	coatings

•	cadmium

•	alloys

•	mercury

•	zinc

29 CFR 1910.252

Training requirements for welding are discussed in Chapter 7, Welding, Cutting, and Brazing.


Welding - Compressed Gas Cylinders

Compressed gas cylinders must be kept away from excessive heat. Cylinders should be stored in assigned places away from elevators, stairs, or gangways. Cylinders must not be stored where they might be damaged or knocked over by passing or falling objects. Cylinders will be stored in a well-ventilated, dry location at least 20 feet away from highly combustible materials.

All cylinders' caps will be in place except when the cylinder is in use or is connected for use.

Acetylene cylinders must be stored in a vertical, valve-end-up position only.

Oxygen cylinders in storage must be separated from fuel-gas cylinders or combustible materials (especially oil or grease):

•	by a minimum distance of at least 20 feet; or

•	by a non-combustible barrier at least five feet high with a fire resistance rating of 1/2 hour or more.

29 CFR 1910.252; 1910.253(b)

Compressed gas is generally discussed in the digest topic, Compressed Gas. Training requirements for use of compressed gas in welding are discussed in Chapter 7, Welding, Cutting, and Brazing.


Welding - Confined Spaces

All welding and cutting operations carried on in confined spaces must be adequately ventilated to prevent the accumulation of toxic materials or possible oxygen deficiency.

In such circumstances, air-line respirators or hose masks must be used. Airline respirators or hose masks must be approved by the National Institute for Occupational Safety and Health (NIOSH).

In areas immediately hazardous to life, hose masks with blowers or self-contained breathing equipment must be used. Breathing equipment must be approved by NIOSH.

For welding operations in confined spaces, or where welders and helpers are provided with hose masks or self-contained breathing equipment, a worker must be stationed on the outside for the safety of the workers inside.

Oxygen may never be used for ventilation.

29 CFR 1910.252(c)(4)


Woodworking Machinery

All woodworking machinery must be guarded to protect the operator and other employees from hazards.

A power control device must be provided on each machine to enable the operator to cut off power on each machine without leaving his or her position at the point of operation.

Power controls and operating controls should be located within easy reach of the operator. The operator must never reach over the cutter to make adjustments. This does not apply to constant pressure controls used only for setup purposes.

Each operating treadle must be protected against unexpected or accidental tripping. Provisions must be made to prevent machines from automatically restarting after a power outage.

29 CFR 1910.213

Training requirements for woodworking machinery are discussed in Chapter 7, Woodworking Machinery.


Workplace Security

Workplace violence has become an increasing cause of workplace injuries and fatalities. In fact, more than a million Americans are attacked or threatened at work every year. Homicide is now the second leading cause of all workplace-related fatalities.

OSHA Guidelines and Recommendations

OSHA does not have specific regulations that apply to workplace violence. However, it has developed two sets of guidelines for the health care/social services industry and night retail establishments--two industries that are particularly susceptible to workplace violence.

These recommendations only address violence that third parties may commit against employees. They do not include violence between co-workers, except to suggest zero tolerance for any kind of violence. The recommendations also do not address the problem of employer liability and responsibility for violence committed by employees against third parties. This is a rapidly growing area of litigation and concern for employers.

General Duty Clause

Employers cannot be cited for failing to comply with the advisory guidelines or recommendations. However, all employers can be cited for failing to protect against workplace violence under the "general duty clause." This clause requires employers to furnish employees with a workplace that is free from recognized hazards that may cause death or serious injury to employees (see General Duty Clause). As incidents of workplace violence have commanded public attention, OSHA has begun to cite more and more employers for such hazards under the general duty clause.

Advantages to Following Recommendations and Guidelines

Though none of the recommendations are mandatory, following them can benefit an employer in several ways. First, OSHA has indicated that it will not cite employers in the particular industries (health care/social services and night retail industries) if the employers effectively implement the guidelines that apply to them. Second, employers in other industries that implement the recommendations are likely to incur OSHA's favor. This makes it considerably less likely that they will be cited under the general duty clause.

Violence Prevention Plan

OSHA's recent recommendations basically suggest that employers establish a workplace violence prevention plan with five essential components:

•	management commitment and employee involvement in violence prevention

•	assessment and analysis of the workplace for such hazards

•	prevention and control of such hazards

•	training on how to prevent such hazards

•	evaluation of the prevention plan

Sample Workplace Violence Prevention Plan

A sample Workplace Violence Prevention Plan is available from Summers Press in its Sample Safety Plans on CD.


Table of Contents

OSHA Training Requirements

Introduction

Building a Training Program

The Role of Training in Safety

Benefits and Limits of Training

Steps for Building a Program

Identifying Training Needs

Designing Learning Activities

Conducting the Training

Evaluating Training Effectiveness

Improving Training Through Feedback

OSHA Training: In General

Two Types of OSHA Training

Training Qualifications

Training Documentation

Time for Training/Retraining

Chart of Periodic Training and Certification Requirements

Specific Training Topics

Alarm Systems

Asbestos

Bloodborne Pathogens

Coke Oven Emissions

Confined Spaces

Control of Hazardous Energy (Lock-Out/Tag-Out)

Cotton Dust

Dip Tanks

Electric Power Generation and Distribution

Emergency Evacuation

Ergonomics

Explosives and Blasting

Fire Brigades

Fire Extinguishers

Fire Safety

Forging Machines

Forklift Operations

Grain Handling Facilities

Hazard Communication

Hazardous Chemicals - Emergency Response

Hazardous Chemicals - Laboratories

Hazardous Chemicals - Specific Substances

Hazardous Waste Operations

Hazardous Waste Treatment, Storage, and Disposal (TSD) Facilities

Helicopters

Laundry Machinery and Operations

Lead

Liquefied Petroleum (LP) Gases

Materials Handling and Storage

Mechanical Power Presses

Medical Services and First Aid

Noise Protection

Personal Protective Equipment (PPE)

Powered Platforms

Process Safety Management of Highly Hazardous Chemicals

Respiratory Protection

Slings

Tank Storage (Floods)

Tanks, Open-Surface

Telecommunications

Welding, Cutting, and Brazing

Woodworking Machinery


Introduction

OSHA Training Requirements

Training is mentioned in over 4,000 places in the OSHA regulations! In fact, worker training may well be the most important part of any safety program. Unsafe practices, the primary cause of employee injuries, are often a direct result of inadequate employee training.

Since an entire book (and a very large one) could be written just on OSHA training requirements, this chapter merely highlights some basic requirements for general industry employers. Employers in particular industries, such as construction or shipbuilding, may be subject to additional or different standards.

This chapter is divided into three parts. The first part examines the role of training in an overall safety program and explains how to identify training needs and implement an effective training program. The second part gives an overview of OSHA training fundamentals, including the different types of training, the documentation required, and the need for retraining. The final part briefly summarizes some of the basic training requirements by topic, along with a citation to the general industry standard (29 CFR Part 1910). These summaries are written in clear "memo English" and are intended to help employers comply with some basic training requirements. The summaries are not intended as a substitute for the full regulation.

A Digest of OSHA Safety Standards for General Industry is located in Chapter 6. It provides an overview of basic safety standards that do not involve training. In addition, Chapter 1 includes material on inspections, citations, and contests, as well as the basic rights and responsibilities of both employers and employees.


Introduction

Building a Training Program

Training plays a critical role in most safety programs. Its purpose is to prevent unsafe work practices, the most common cause of employee injuries. In building a program, the employer must identify the training needs of employees, design learning activities, and monitor the training to make sure it is effective.


The Role of Training in Safety

Training is very important, but it is only part of the whole safety and health picture. Training must be implemented within the context of an effective overall safety program. The following elements generally are found in any successful safety program:

•	management's complete commitment to accident prevention

•	a belief that injuries arise from preventable causes

•	extensive worker involvement in safety

•	an emphasis on safety training

•	a sense that the safety program is not an expense, but a benefit


Benefits and Limits of Training

Training is essential to the success of every safety and health program. It is especially helpful to new or inexperienced workers, who are most prone to injury. Effective training helps to:

•	ensure employee health and safety;

•	improve employee relations and communication;

•	reduce accidents and related workers' compensation costs;

•	reduce the risk of OSHA fines and citations;

•	improve employee efficiency and productivity; and

•	enhance the employer's public image because of a better safety record.

Although training can improve workers' skills and performance, it also requires the cooperation and interest of workers. Poorly motivated and uninterested workers will not benefit from any training they are given. Finally, no amount of training can overcome the risks posed by faulty workplace design and slipshod engineering. Are hazardous conditions or engineering deficiencies the real culprits in causing injuries? If so, those problems need to be addressed outside of the training program.


Steps for Building a Program

Effective training programs do not just happen by accident. They require careful planning, clear goals, dedicated instructors, and motivated students. Whether the activity is athletics, academics, or occupational safety and health, successful training follows five basic steps:

•	identifying training needs

•	designing learning activities

•	conducting the training

•	evaluating training effectiveness

•	improving training through feedback


Identifying Training Needs

Establish what the worker is expected to do and identify hazardous tasks. Analyze each task to determine what the worker must learn to do the job safely.


Designing Learning Activities

Learning activities should enable workers to demonstrate their competence. Activities should simulate actual job tasks as closely as possible. Learning can be group-oriented, with lectures, role-playing, and demonstrations; or it can be self-paced for individual workers. Ultimately, the design depends on the employer's creativity and training resources and the needs of employees.


Conducting the Training

To successfully conduct training, a business must do all of the following:

•	Plan the training structure and format.

•	Consider the number, frequency, and length of sessions.

•	Select who will do the training.

•	Determine instructional techniques.

•	Organize the training and clearly define its objectives.

•	Give workers an overview of what they will learn.

•	Relate training materials to tasks and jobs. (Whenever possible, include hands-on experience and role-playing activities.)

•	Reinforce learning by summarizing objectives and key concepts.

•	Encourage workers to participate in discussions and to ask questions.


Evaluating Training Effectiveness

To evaluate whether training is accomplishing its objectives, an employee must do all of the following:

•	Develop a plan to objectively evaluate training effectiveness.

•	Ask workers what they have learned through training.

•	Ask supervisors if workers are accomplishing training goals.

•	Look for positive trends in injury/illness statistics from training.


Improving Training Through Feedback

Collect and evaluate feedback from workers, supervisors, and other persons affected by the training. Consider the following:

•	Did the training focus on critical elements of the job?

•	Were gaps in workers' knowledge or skills covered?

•	Were the training objectives presented clearly?

•	Were workers motivated to learn?

•	Were workers encouraged to participate and to ask questions?

•	Did the objectives state the performance levels expected of workers?

•	Did learning activities simulate actual work tasks?

•	Were learning activities suitable for the skills that the jobs required?

•	Were training materials presented in a clear and organized fashion?

Adjust the training program in accordance with any helpful feedback that is received.


Introduction

OSHA Training: In General

The duty to train workers for their safety may be found in both specific OSHA regulations and in the general duty clause. Under the general duty clause, employers must furnish a workplace free from recognized hazards that could cause death or serious injury to employees (see General Duty Clause). Under specific regulations, employers must teach workers how to avoid particular hazards and to safely do their jobs.

As in other areas of safety regulation, states with OSHA-approved plans may have different training standards than federal OSHA as long as they are at least as effective (see Chapter 8).


Two Types of OSHA Training

OSHA regulations provide for two types of training:

•	general training: alerts workers to the safety and health aspects of their jobs

•	specific training: trains workers who do specific tasks or jobs

For example, all workers who may be exposed to electric shock hazards must be given general training on avoiding those hazards. On the other hand, workers who are qualified to work on or near exposed live current must receive detailed specific training on safe clearance distances, insulated tools, etc.


Training Qualifications

OSHA often requires a "certified person," "competent person," or "qualified person" to perform certain tasks or to instruct workers who need specific training. A "certified person" usually has received a certification of training or ability from an employer or professional organization. A "competent person" is capable of identifying and correcting workplace hazards. A "qualified person" has demonstrated the ability to resolve problems because of a recognized degree, certificate, or professional standing; or because of extensive knowledge, training, and experience.


Training Documentation

OSHA generally requires employers to document their training efforts and to provide all materials for any required training program to OSHA on request. Specific training regulations usually require employers to keep training materials for at least the duration of a worker's employment, if not longer.

OSHA sometimes requires a "certification" to establish training. A certification is written documentation verifying that the employee understands the training and can apply it in the workplace. The Chart of Periodic Training and Certification Requirements lists some of the training topics for which certification is required. This information is also discussed in Specific Training Topics.


Time for Training/Retraining

Generally speaking, OSHA requires employees to receive any required training before their initial job assignments. This is simply common sense. Employers must train workers in safety before they encounter a particular danger. Otherwise, the training will not do them much good.

In addition, OSHA generally requires the employer to retrain employees whenever:

•	the employee's performance reveals a need for additional training; or

•	changes in equipment, technology, or work practices render the previous training ineffective.

Finally, a number of OSHA training regulations specifically require that workers be retrained every year or during some other fixed period. The Chart of Periodic Training and Certification Requirements lists some of the training topics for which periodic retraining is required. This information is also discussed in Specific Training Topics.


Chart of Periodic Training and Certification Requirements

The following chart lists some of the major subjects (not a complete list) for which OSHA specifies periodic retraining requirements, written certification of training, or both. The periods listed for retraining represent the minimum standard. In addition to complying with specific standards for periodic retraining, employers must always retrain employees if there are problems in their performance or changes in the workplace (see Time for Training/Retraining).

Training Frequency and Certification

Topic	Frequency	Certification

1,3-Butadiene	annual training	no

2-Acetylaminofluorene	review annually	no

3,3-Dichlorobenzidine	review annually	no

4-Aminodiphenyl	review annually	no

4-Dimethylaminoazobenzene	review annually	no

4-Nitrobiphenyl	review annually	no

Acrylonitrile	review annually	no

Alpha-Napthylamine	review annually	no

Asbestos	annual training	no

Benzene	annual training	no

Benzidine	annual training	no

Beta-Napthylamine	annual training	no

Beta-Propiolactone	annual training	no

Bis-Chloromethyl Ether	annual training	no

Bloodborne Pathogens	annual training	no

Cadmium	annual training	yes

Coke Oven Emissions	annual training	no

Cotton Dust	annual training	no

Control of Hazardous	annual inspection to	yes

Energy (Lock-Out/	verify compliance

Tag-Out)

Crane Operations	training card	yes

Electric Power Generation,	regular supervision/	yes

Transmission, and	annual inspection

Distribution

Ethylene Oxide	annual training	no

Ethyleneimine	annual training	no

Fire Brigades	annual training; 	no

quarterly for those

who do interior

structural fire fighting

Fire Extinguishers	annual training	no

Fire Protection and	annual training for 	no

Prevention 	fixed extinguishing

systems; annual for

fire-fighting activities

Forklift Operators	every three years	yes

Formaldehyde	annual training	no

Grain Handling Facilities	annual training	no

Hazard Communication,	whenever a new 	no

General	hazard is introduced

in the work area

Hazardous Chemicals	annual training	no

(Emergency Response)

Hazardous Waste	annual training	yes

Operations

Hazardous Waste	annual training	yes

Treatment, Storage,

and Disposal Facilities

Inorganic Arsenic	quarterly for workers	no

who use respirators,

annually for other

workers

Lead	annual training	no

Mechanical Power Presses	annual training	yes

Medical and First Aid	as necessary to remain	no

Persons	remain proficient

Methyl Chloromethyl Ether	annual training	no

Methylene Chloride	whenever there are 	no

workplace changes

that increase

workplace exposure

Methylene Dianiline (MDA)	annual training	no

N-Nitroso-Dimethylamine	annual training	no

Noise Exposure	annual training, 	no

for each worker in a

hearing conservation

program

Permit-Required	as necessary to	yes

Confined Spaces	maintain proficiency

Personal Protective	initial assignment 	yes

Equipment (PPE)

Powered Platforms	initial assignment	yes

Process Safety Management	every three years	yes

Respirator	annual training	no

Telecommunications	initial assignment	yes

Vinyl Chloride	annual training	no


Introduction

Specific Training Topics

Brief summaries are provided below of some basic training requirements for selected topic areas. The topics discussed include some of the more common and important areas. However, the extensiveness of the OSHA training regulations means that there are many specific training subjects that cannot be addressed in a single chapter.


Alarm Systems

Employers must:

•	establish procedures for sounding emergency alarms in the workplace; and

•	inform workers how to report workplace emergencies.

Servicing, maintenance, and testing of employee alarms must be done by trained personnel.

29 CFR 1910.165(d)(5)

A related topic, Emergency Action Plans, is discussed in Chapter 6.


Asbestos

Employers must provide training for all workers exposed to airborne concentrations of asbestos at or above either the time-weighted average limit (asbestos of over 0.1 fiber per cubic centimeter of air as an eight-hour time-weighted average) or the excursion limit (asbestos of over 1.0 fiber per cubic centimeter as averaged over a sampling period of 30 minutes).

The training must be provided on the employee's job assignment and must be repeated at least annually thereafter. The program method must enable employees to understand the subject matter.

29 CFR 1910.1001(j)(7)

Program Elements

The program must include information on all of the following:

•	health effects associated with asbestos

•	relationship of smoking and asbestos exposure to lung cancer

•	the amount, location, use, storage, and release of asbestos

•	specific operations that could cause asbestos exposure

•	engineering controls and job practices related to the employee's job

•	applicable work practices, emergency and cleanup procedures, and personal protective equipment (PPE)

•	use and limits of respirators and protective clothing

•	purpose and description of required medical surveillance program

•	materials on stopping smoking from public health organizations

•	required signs and labels

Housekeeping Employees

At least annually, employers must provide an asbestos training awareness course for employees who perform housekeeping work in areas with asbestos-containing materials (ACM) or presumed asbestos-containing materials (PACM).

29 CFR 1910.1001(j)(7)(iv)

Pulmonary Function Testing

Persons other than licensed physicians who administer pulmonary function testing must complete a training course in spirometry sponsored by an appropriate academic or professional institution.

29 CFR 1910.1001(l)(1)(ii)(B)

Training Records

The employer must maintain training records for one year beyond a worker's last employment date and make them available to OSHA on request.

29 CFR 1910.1001(m)

Asbestos is also discussed in Chapter 6.


Bloodborne Pathogens

Workers exposed to bloodborne pathogens must be trained at the time of their initial assignment and at least annually thereafter. In addition, employers must provide additional training whenever changes in the workplace alter an employee's exposure.

29 CFR 1910.1030(g)(2)

Training must:

•	be based on "user friendly" materials that are suitable for workers;

•	allow workers the chance to question and interact with the trainer; and

•	be conducted by a trainer who knows the Bloodborne Pathogens Standard and its application to the particular workplace at issue.

29 CFR 1910.1030(g)(2)

Training Program Elements

Training must cover all of the following elements:

•	the Bloodborne Pathogen Standard (including an actual copy)

•	the symptoms and transmission of bloodborne pathogens

•	the Exposure Control Plan, including how to obtain a copy

•	recognizing tasks that may involve exposure to bloodborne pathogens

•	methods to reduce bloodborne pathogens exposure

•	personal protective equipment (PPE), including its selection, location, removal, decontamination, and disposal

•	hepatitis B vaccine, including its benefits, administration, safety, and availability without charge

•	appropriate actions and contact persons for emergencies involving blood or other potentially infectious materials

•	reporting and other required procedures if an exposure occurs

•	required post-exposure evaluation and follow-up

•	signs, labels, and required color-coding

29 CFR 1910.1030(g)(2)

Needlestick Safety and Prevention Act of 2000

Under the Needlestick Safety and Prevention Act of 2000, employers must seek input from non-managerial employees who:

•	are involved in direct patient care; and

•	have potential occupational exposure to contaminated sharps.

The input must address effective engineering and work practice controls for protection from contaminated sharps. Training and education in the use of safer medical devices and safer work practices is the major purpose of the Act (see Bloodborne Pathogens).

Training Records

Training records must be kept for at least three years and must include the dates of training sessions, a summary of training session materials, names and qualifications of persons conducting training, and names and job titles of all persons attending training.

29 CFR 1910.1030(h)(2)

HIV/HBV Laboratories and Production Facilities

Employees who work in HIV or HBV laboratories or production facilities must meet numerous additional training requirements.

29 CFR 1910.1030(d)(2)(ii)(M) and (g)(2)(ix)

Related topics discussed in Chapter 6 include Bloodborne Pathogens, Hepatitis B Vaccination, and Infectious Materials. A sample Bloodborne Pathogens Exposure Control Plan is available from Summers Press in its Sample Safety Plans on CD.


Coke Oven Emissions

At the time of an employee's initial assignment to a regulated area (and at least annually thereafter), employers must provide training in the health hazards from coke oven emissions. The program must cover all of the following:

•	the information contained in the substance information sheet for coke oven emissions (29 CFR 1910.1029, Appendix A)

•	the purpose, proper use, and limitations of respirators

•	a description and explanation of the medical surveillance program

•	a review of:

-	all written procedures and schedules to reduce exposure

-	the coke oven emission standard

29 CFR 1910.1029(k)


Confined Spaces

Employers must train workers exposed to permit-required confined space hazards to enable them to safely perform their duties. Training must be provided:

•	before any employee is first assigned to duties;

•	before any changes are made in assigned duties;

•	before any changes are made in permit space operations for which the employee has not been trained; and

•	whenever workers are deviating from proper entry procedures.

29 CFR 1910.146(g)

Certification

The employer must certify in writing that covered workers have accomplished the training. The certification must include each worker's name, the signatures or initials of the trainers, and the training dates.

29 CFR 1910.146(g)(4)

Entrants/Attendants

Entrants and attendants must meet special requirements that are listed below.

•	Entrants must be trained in all of the following:

-	hazards that may be faced during entry

-	using equipment for testing, monitoring, and ventilating

-	communicating with attendants

-	alerting attendants to dangerous situations and prohibited conditions

-	evacuating whenever an order is given or a dangerous condition exists

•	Attendants must be trained in all of the following:

-	hazards that may be faced during entry

-	behavioral effects of hazard exposure in authorized entrants

-	accurately identifying and counting authorized entrants

-	remaining outside the permit space until being relieved

-	monitoring and communicating with entrants

-	ordering necessary evacuations

-	summoning emergency help if a rescue may be necessary

-	preventing entry by unauthorized persons

-	performing non-entry rescues

-	refraining from any activities that could interfere with their primary duty of monitoring and protecting authorized entrants

29 CFR 1910.146(h) and (j)

Rescue Team

The employer must make sure that each member of a rescue team receives:

•	equipment and training necessary for performing assigned duties and for performing permit space rescues;

•	training required for authorized entrants under the OSHA standard;

•	training for performing basic first aid and CPR (in addition, at least one rescue member must hold a current certification in first aid); and

•	annual training in simulated rescues where mannequins, dummies, or actual persons are removed.

Attendants may enter a permit space to attempt a rescue only if:

•	they have received required training and equipment for rescue operations; and

•	they have been relieved by another attendant.

29 CFR 1910.146(k)(1)

Confined spaces are discussed in the digest topic, Confined Spaces. A sample Confined Space Plan is available from Summers Press in its Sample Safety Plans on CD.


Control of Hazardous Energy (Lock-Out/Tag-Out)

Employers must establish energy control procedures, training, and periodic inspections to make sure that workers can safely service machinery and equipment. "Authorized" workers must have training in using and removing energy controls. All other persons who work in areas with energy control procedures ("affected" and "other" workers) must know the procedures. When tag-out systems are used, workers must be trained in the limitations of tags.

29 CFR 1910.147

The employer must certify in writing that workers are trained and their training is current. The certification must contain each worker's name and training dates.

29 CFR 1910.147(c)(7)(iv)

At least annually, the employer must conduct a periodic inspection of the energy control procedures. The inspection must be:

•	performed by someone other than the employees who are using the energy control procedures; and

•	certified in writing, including the date, employees inspected, employees performing the inspection, and equipment inspected.

29 CFR 1910.147(c)(6)

Each lock or tag must be removed from its energy-isolating device by the worker who applied it. However, an exception applies when the authorized worker who applied the lock or tag is unavailable to remove it. Then, the lock-out or tag-out device may be removed under the employer's direction if procedures and training for removal are part of the energy control program.

29 CFR 1910.147(e)(3)

Control of hazardous energy is discussed in the digest topic, Control of Hazardous Energy (Lock-Out/Tag-Out). A sample Lock-Out/Tag-Out Plan is available from Summers Press in its Sample Safety Plans on CD.


Cotton Dust

For workers exposed to cotton dust, employers generally must provide training before initial assignment and at least annually thereafter. Additional training must be provided if needed because of changes in job tasks or because of poor employee performance.

Employees who work with certain kinds of cotton are exempt from the training requirements. This exemption applies to workers who use medical grade cotton (USP), mercerized yarn, and certain lower-grade washed cotton. In December of 2000, OSHA expanded the last category to include cotton cleaned in "batch kier washing systems."

Training must address all of the following for covered employees:

•	acute and chronic health hazards from cotton dust exposure

•	jobs and processes that could cause exposure above the permissible exposure limit (PEL)

•	measures to protect employees from exposures above the PEL

•	use and limitations of respirators

•	a description and explanation of the medical surveillance program

•	the cotton dust standard and its appendices

29 CFR 1910.1043(i)(1)

Persons other than licensed physicians who administer the pulmonary function test must complete a NIOSH-approved training course in spirometry.

29 CFR 1910.1043(h)(1)(iii)


Dip Tanks

Employees must know the first aid procedures that are appropriate for the dipping or coating hazards to which they are exposed.

29 CFR 1910.124(f)


Electric Power Generation and Distribution

Workers exposed to electric shock hazards from electric power generation, control, transmission, and distribution lines and equipment must be trained in safety requirements relevant to their jobs. Both "qualified" and "unqualified" persons must be trained.

29 CFR 1910.269(a)(2)

"Unqualified persons" have not been trained to work on or near exposed energized parts but may still be exposed to electrical hazards. They must be trained in any safety-related work practices and procedures that are relevant to their job assignments.

29 CFR 1910.269(a)(2)

"Qualified persons" are those who are specifically authorized to work on or near exposed energized parts. Qualified persons must be trained and competent in all of the following:

•	distinguishing exposed live parts from other parts of electrical equipment

•	determining the nominal voltage of exposed live parts

•	safe clearance distances (vary depending on voltage exposures)

•	special techniques, protective equipment, insulating materials, and insulated tools for working on or near exposed energized parts

•	any other safety practices and emergency procedures needed for their work safety (e.g., pole top and manhole rescue)

29 CFR 1910.269(a)(2)

Training Frequency

Employers must determine that each employee is complying with the safety-related work practices through regular supervision and inspections conducted at least annually.

29 CFR 1910.269(a)(2)

Certification

The employer must certify in writing that each employee has received the required training and has attained the necessary proficiency. The certification must be kept for the duration of the employee's employment. Certification may be made through employment records that indicate receipt of the required training.

29 CFR 1910.269(a)(2)(vii)

Cardiopulmonary Resuscitation (CPR) and First Aid Training

Persons trained in first aid (including CPR) must be on-site if anyone works on exposed lines or equipment energized at 50 volts or more. If two or more persons are doing field work, at least two trained persons must be available. However, if all new workers are trained in first aid and CPR within three months of their hiring dates, only one person need be available.

29 CFR 1910.269(b)(1)

At fixed work locations such as generating stations, a person trained in first aid and CPR must be able to reach any shocked worker within four minutes.

29 CFR 1910.269(b)(1)

Enclosed Spaces

Workers who enter enclosed spaces or who serve as attendants must be trained in enclosed space hazards and entry and rescue procedures. [Note: Employers must also make sure that employees comply with any applicable permit-space entry requirements of 29 CFR 1910.146(d)-(k).] (See Control of Hazardous Energy.)

29 CFR 1910.269(e)(2)

Servicing Equipment

In installations for electric power generation, the employer must have an energy control program so that machines are isolated from their energy sources before anyone works on them. Each worker must be trained to recognize hazardous energy sources, isolate them, and control the energy. Workers who use tag-out systems must be trained to use them appropriately. (See Control of Hazardous Energy.)

29 CFR 1910.269(a)(2)(d)

Related topics discussed in Chapter 6 include Electrical Safety-Related Work Practices and Electrical Utilization Equipment.


Emergency Evacuation

Before implementing an Emergency Action Plan, the employer must designate and train enough persons for a safe, orderly evacuation.

29 CFR 1910.38(a)(5)

Emergency action plans are also discussed in the digest topic, Emergency Action Plans. A Sample Emergency Action Plan is located in Chapter 3.


Ergonomics

Employers that want to reduce musculoskeletal disorders (MSDs), which are also known as cumulative trauma disorders (CTDs) and repetitive motion injuries (RMIs), need to train their employees in basic ergonomic principles (see digest topic, Ergonomics).


Explosives and Blasting

Every motor vehicle transporting Class A or Class B explosives must be attended by a person who:

•	knows the class and danger of the explosive material; and

•	is trained to protect the public from those dangers.

29 CFR 1910.109(g)(3)(iii)(a)

Explosives and blasting agents are also discussed in the digest topic, Explosives and Blasting Agents.


Fire Brigades

Employers that establish fire brigades must train all brigade members before they begin brigade activities. The training must be appropriate for the duties that each member is expected to perform. Leaders and training instructors require more comprehensive training than other brigade members. Training must be similar to programs offered by schools such as the Maryland Fire and Rescue Institute, Iowa Fire Service Extension, or Washington State's Fire Service Training Commission for Vocational Education.

29 CFR 1910.156(c)(3)

Training must be conducted at least annually; fire brigade members who do interior structural fire fighting must be trained at least quarterly.

29 CFR 1910.156(c)(2)

Employers must train fire brigade members about workplace hazards such as flammable liquids and gases, toxic chemicals, radioactive sources, and water-reactive substances. Employers must develop and make available for inspection written procedures on how to deal with special hazards.

29 CFR 1910.156(c)(4)


Fire Extinguishers

When the employer provides portable fire extinguishers, it must educate employees about the general principles of their use and the hazards of fighting a fire in its early stages. The training must be made on each employee's initial assignment and at least annually thereafter.

29 CFR 1910.157(g)

Workers designated in an Emergency Action Plan to use fire-fighting equipment must be trained by the employer before their initial assignment and at least annually thereafter.

29 CFR 1910.157(g)

Instead of Class A portable fire extinguishers, employers may use uniformly spaced standpipe systems or hose systems connected to a sprinkler system if:

•	the systems meet 29 CFR 1910.158 or 1910.159 requirements;

•	the systems cover the area to be protected; and

•	workers are annually trained to use them.

29 CFR 1910.157(d)(3)

Hydrostatic testing must be performed by trained persons with appropriate testing equipment.

29 CFR 1910.157(f)(1)

Fire extinguishers are also discussed in the digest topic, Fire Extinguishers.


Fire Safety

On each worker's initial assignment, the employer must:

•	review parts of the fire prevention plan that the worker must know in an emergency; and

•	inform workers about fire hazards to which they might be exposed.

29 CFR 1910.38(b)(4)

Employers must designate trained persons to inspect standpipe and hose systems.

29 CFR 1910.158(e)(2)(vi)

The employer must be sure that fire detection systems are serviced, maintained, and tested by trained persons.

29 CFR 1910.164(c)(4)

The employer must:

•	train designated workers to inspect and maintain fixed extinguishing systems; and

•	annually review their training.

29 CFR 1910.160(b)(10)

Fire safety is also discussed in the digest topic, Fire Safety. A Sample Fire Safety Plan is provided in Chapter 3.


Forging Machines

The employer must maintain all forge shop equipment so that it will operate safely. This responsibility includes training workers to properly inspect and maintain equipment.

29 CFR 1910.218(a)(2)(iii)


Forklift Operations

Employers that use powered industrial forklift trucks must train operators in their safe operation. Only trained operators who have successfully completed a training program and received a written certification are permitted to operate a powered industrial forklift truck. However, trainees under the direct supervision of a designated person may operate a forklift in areas where it is safe to do so if other employees are not endangered.

29 CFR 1910.178(l)

Training Methodology

Training must involve a combination of all of the following elements:

•	formal instruction (e.g., lecture, videotapes, interactive computer training, written materials, discussion)

•	practical training (demonstrations performed by the trainer and practical exercises performed by the trainee)

•	evaluation of the operator's ability to actually apply the training to the workplace (i.e., the operator must pass an actual driving evaluation before his or her initial job assignment)

29 CFR 1910.178(l)(2)

Qualifications of Trainers

All training must be conducted by persons who have the knowledge and experience to train forklift operators and to judge their competency. Trainers may be from outside the employer's organization. Trainers need not have any special accreditation, but must be fully capable of doing the job.

29 CFR 1910.178(l)(B)(iii)

Required Training Topics

All of the following topics must be covered as part of the training program unless the employer can show that a particular topic does not apply to its workplace. For example, if a forklift is not used in a hazardous environment of gases or vapors, there would be no required training in that element. If a forklift is operated only on smooth concrete surfaces, there would be no need for training in driving the forklift on rough terrain.

Truck-Related Topics

•	instructions and precautions for the types of truck the operator will drive

•	differences from automobiles

•	using seat belts and following the manufacturer's instructions and precautions (required if operator restraint systems are provided by the manufacturer)

•	location and operation of controls and instrumentation

•	engine operation and maintenance

•	steering and maneuvering

•	visibility (including restrictions caused by loading)

•	the use and limits of forks and attachments

•	vehicle capacity and stability

•	vehicle inspection and maintenance

•	refueling engines and recharging batteries

•	operating limitations and necessary warnings

Workplace-Related Topics

•	the composition of probable loads and ensuring load stability

•	manipulating, stacking, and unstacking loads

•	narrow aisles and other restricted places of operation

•	pedestrian traffic

•	operating in hazardous (classified) locations

•	operating on ramps or other sloped surfaces that could affect the vehicle's stability

•	operating in closed environments where poor ventilation could cause a buildup of carbon monoxide or diesel exhaust

•	any unique or potentially hazardous environments that exist or may exist in the workplace

29 CFR 1910.178(l)(3)

Written Certification

The employer must certify in writing that the employee has received necessary training and has shown the competence to safely perform forklift operations. The certification must include the following:

•	name of the trainee

•	dates of training

•	signature of the person performing the training or evaluation

The employer need not retain the current training materials and course outline. If an outside trainer was used, the employer must retain his or her name and address.

29 CFR 1910.178(l)(6)

Refresher and Remedial Training

Refresher training is required at least every three years. In addition, remedial training is required in case of:

•	any forklift accident, near-miss accident, or instance of unsafe operation;

•	any evaluation indicating that the operator needs retraining; or

•	any assignment for which the operator must drive another type of forklift or work in substantially different or changed conditions.

In addition, the trainer who does the refresher training must perform an evaluation to ensure its effectiveness.

29 CFR 1910.178(l)(4)

Evaluating Previous Training

An employer need not provide forklift training, whether for an existing employee or a new hire, if an evaluation indicates that the employee's previous training is sufficient. However, some additional training will still be needed:

•	if the evaluation indicates a need for further training;

•	if there are any substantial changes in the workplace; or

•	if the employee is going to operate a new type of powered industrial forklift truck.

Some site-specific training will almost always be necessary even if an evaluation indicates a general competence on the part of an employee.

29 CFR 1910.178(l)(5)

Related Topics

Forklift operations are discussed in the digest topic, Forklift Operations. A sample Forklift Safety Plan is available from Summers Press in its Sample Safety Plans on CD.


Grain Handling Facilities

Employers must train workers before they start work and at least annually thereafter. In addition, employees must be trained whenever changes in job assignments may expose them to new hazards at grain handling facilities.

Workers must be trained in all of the following:

•	general safety precautions, including common ignition sources (e.g., smoking) and measures to prevent dust accumulation

•	specific job-related safety practices, including:

-	cleaning grinding equipment

-	clearing choked legs

-	housekeeping and hot work procedures

-	lock-out/tag-out procedures

-	preventive maintenance procedures

29 CFR 1910.272(e)(1)

Special Tasks

Workers assigned special tasks such as entering bins and handling flammable or toxic substances must be trained to perform the tasks safely. Employees who enter grain storage areas must be informed in the prevention of engulfment and mechanical hazards.

29 CFR 1910.272(e)(2)

Observers

Workers acting as observers must be trained in rescue procedures, including procedures for obtaining assistance.

29 CFR 1910.272(g)(5)

Informing Contractors

The employer must inform contractors working at grain handling facilities of potential fire and explosion hazards. The employer must also inform contractors of a facility's safety rules and explain applicable provisions of the Emergency Action Plan.

29 CFR 1910.272(h)(3)(i)


Hazard Communication

Employers must provide workers with training and information on hazardous chemicals in their work areas at the time of initial assignment and whenever a new hazard is introduced. Training and information must cover the following:

•	requirements of the Hazard Communication Standard

•	operations in their work area where hazardous chemicals are present

•	location of the written Hazard Communication Plan

•	methods to detect hazardous chemicals in the work area

•	hazards of chemicals in the work area

•	methods for protection from chemical hazards, such as appropriate work practices, emergency procedures, and protective equipment

•	details of the Hazard Communication Plan, including how to use the Material Data Safety Sheet and other hazard information

29 CFR 1910.1200

Hazard communication and MSDSs are discussed in Chapter 2. A Sample Hazard Communication Plan is provided in Chapter 3.


Hazardous Chemicals - Emergency Response

Persons who respond to hazardous chemical emergencies, including all employees involved in hazardous waste operations, must be extensively trained according to one of the following classifications:

•	first responder awareness level: likely to see or encounter a hazardous substance release and responsible for notifying authorities

•	first responder operations level: acts to protect persons and property; acts to contain releases from a safe distance and prevent exposures

•	hazardous materials technician: acts to stop a hazardous release and takes a more aggressive role than first responders at the operations level

•	hazardous materials specialist: supports hazardous materials technicians and must have a more specific knowledge of substances to contain

•	on-scene incident commander: assumes control of the incident scene beyond the first responder awareness level and is aware of the state emergency response plan and the Federal Regional Response Team

Workers in each classification must meet detailed and specific training requirements applicable to their particular classification before participating in actual emergency operations. In addition, workers must have annual refresher training or demonstrate their competence annually.

29 CFR 1910.120(q)(b)

Statement of Competency

For each trained worker, the employer must issue a statement of competency and keep a record of the method used to show competency.

29 CFR 1910.120(q)(8)

Trainers

Trainers who teach the different responder levels must complete training courses for teaching their subjects or have equivalent academic credentials and instructional experience.

29 CFR 1910.120(q)(7)

For training of workers involved in cleanup operations under RCRA, CERCLA, or similar laws, see Hazardous Waste Operations. For training of workers at treatment, storage, and disposal (TSD) facilities, see Hazardous Waste Treatment, Storage, and Disposal (TSD) Facilities.


Hazardous Chemicals - Laboratories

Employers must train workers who work in laboratories about the chemical hazards in their work area before initial assignments and assignments involving new chemical exposures. Training must cover all of the following:

•	chemical hazards in the work area, including methods to detect them

•	protective measures for chemical hazards and applicable details of the written Chemical Hygiene Plan

In addition, employees must be informed of the following before their initial job exposure:

•	contents of the standard and appendices

•	location and availability of the Chemical Hygiene Plan

•	permissible exposure limits for hazardous substances

•	signs and symptoms of hazardous chemical exposures

•	location and availability of known reference materials (e.g., Material Data Safety Sheets) on the hazards, safe handling, and storage of hazardous chemicals

29 CFR 1910.1450(f)(4)(ii)


Hazardous Chemicals - Specific Substances

There are a number of chemicals for which specific employee training is required. Among the most important ones (not a complete list) are the following:

1,3-Butadiene	29 CFR 1910.1051(l)(2)

2-Acetylaminofluorene	29 CFR 1910.1014(e)(5)

3,3-Dichlorobenzidine	29 CFR 1910.1007(e)(2)

4-Aminodiphenyl	29 CFR 1910.1011(e)(5)

4-Dimethylaminoazobenzene	29 CFR 1910.1015(e)(5)

4-Nitrobiphenyl	29 CFR 1910.1003(e)(5)

Acrylonitrile	29 CFR 1910.1045(o)(1)

Alpha-Napthylamine	29 CFR 1910.1004(e)(5)

Benzene	29 CFR 1910.1028(j)(3)

Benzidine	29 CFR 1910.1010(e)(5)

Beta-Napthylamine	29 CFR 1910.1009(e)(5)

Beta-Propiolactone	29 CFR 1910.1013(e)(5)

Bis-Chloromethyl Ether	29 CFR 1910.1008(e)(5)

Cadmium	29 CFR 1910.1027(m)(4)

Ethylene Oxide	29 CFR 1910.1047(j)(3)

Ethyleneimine	29 CFR 1910.1012(e)(5)

Formaldehyde	29 CFR 1910.1048(n)

Inorganic Arsenic	29 CFR 1910.1018(o)

Methyl Chloromethyl Ether	29 CFR 1910.1006(e)(5)

Methylene Chloride	29 CFR 1910.1052(i)

Methylene Dianiline (MDA)	29 CFR 1910.1050(k)(3)

N-Nitroso-dimethylamine	29 CFR 1910.1016(e)(5)

Vinyl Chloride	29 CFR 1910.1017(j)


Hazardous Waste Operations

Workers who participate in cleanup operations at sites covered by RCRA (the Resource Conservation and Recovery Act of 1976), CERCLA (the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 or "Superfund Act"), or similar state or local laws must be informed of any risks from hazardous waste operations and must be trained before they either are exposed to hazardous waste or are permitted to do hazardous waste work. Workers cannot participate in or supervise field activities until they have been trained at the level required for their jobs and responsibilities.

29 CFR 1910.120(c)(7) and (e)

Training must cover all of the following:

•	names of personnel and alternates responsible for workplace safety

•	hazards on the site

•	use of personal protective equipment

•	safe work practices

•	engineering controls and equipment used on-site

•	medical surveillance requirements

•	contents of the site-specific safety and health plan

29 CFR 1910.120(e)

All persons who are exposed to hazardous waste operations on-site must also have eight hours of annual refresher training.

29 CFR 1910.120(8)

Different Requirements for Different Workers

•	General site workers (such as equipment operators, general laborers, and supervisory personnel) who are exposed to hazardous substances must have at least 40 hours of instruction and three days of supervised field experience from a trained, experienced supervisor.

•	Workers who are on-site only occasionally to accomplish a specific task and who are unlikely to be exposed over permissible exposure limits must have at least 24 hours of instruction and one day of supervised field experience from a trained, experienced supervisor.

•	Workers regularly on-site who work in safe areas (i.e., where exposures are under permissible limits, where respirators are unnecessary, and where there are no health hazards or the possibility of an emergency) must have at least 24 hours of instruction and one day of supervised field experience.

29 CFR 1910.120(e)(3)(iii)

Management and Supervisor Training

On-site managers and supervisors directly responsible for workers engaged in hazardous waste operations generally must have 40 hours of instruction, three days of supervised field experience, and at least eight additional hours of specialized training. Training may be reduced to 24 hours and one day of supervised field experience for someone who supervises workers:

•	who are on-site only occasionally; or

•	who work in areas where hazards do not exceed permissible exposure limits and where respirators are not required.

29 CFR 1910.120(e)(4)

Emergency Response Plan and Training

All hazardous waste employers must develop an emergency response plan. The plan must be rehearsed regularly as part of an overall training program for site operations. In addition, employees who respond to hazardous waste emergencies must be trained in how to properly respond (see Hazardous Chemicals - Emergency Response).

29 CFR 1910.120(e)(7) and (p)(8)(iv)(c)

Certification

Each person who successfully completes training and field experience is required to receive a written certification from his or her instructor. A certification is required before doing hazardous waste work.

29 CFR 1910.120(e)(6)

Related Topics

Hazardous waste operations are discussed in the digest topic, Hazardous Waste Operations. For training of workers at treatment, storage, and disposal (TSD) facilities under the Resource Conservation and Recovery Act (RCRA), see Hazardous Waste Treatment, Storage, and Disposal (TSD) Facilities. For training of emergency response workers for chemical spills, see Hazardous Chemicals - Emergency Response.


Hazardous Waste Treatment, Storage, and Disposal (TSD) Facilities

Employers must train workers exposed to health hazards or hazardous substances at treatment, storage, and disposal facilities under the Resource Conservation and Recovery Act (RCRA). New workers must have at least 24 hours of initial training and eight hours of annual refresher training. Successful completion of initial training must be established by a written certificate. Employers can waive initial training if the worker's previous experience or training is equivalent to the initial training requirements. However, eight hours of annual refresher training is still required.

29 CFR 1910.120(p)(7)

Emergency Response

Emergency response employees must be trained before they respond to real emergencies. Training must cover the emergency response plan, standard operating procedures, emergency procedures, and use of personal protective equipment. However, an employer need not train all workers for emergency response activities if enough workers have the necessary training to properly perform the emergency response, or if advance arrangements have been made for an outside emergency team. However, all untrained workers must still be able to recognize an emergency and summon the response team.

29 CFR 1910.120(p)(8)(iii)

Members of disposal facility emergency response teams must be trained to recognize health and safety hazards so they can protect themselves and other workers.

29 CFR 1910.120(p)(8)(iii)(B)

Responders must regularly rehearse the emergency response plan as part of the overall training program for site operations.

29 CFR 1910.120(p)(8)(iv)(C)

Certification

At least yearly, employers must certify in writing that each covered worker:

•	has successfully completed emergency response training; or

•	is competent in responding to an emergency.

29 CFR 1910.120(p)(8)(iii)(C)

Trainer Qualifications

Trainers must complete a training course for teaching or have equivalent academic credentials and experience.

29 CFR 1910.120(p)(7)(iii)

For training of workers under RCRA, CERCLA, and similar laws (other than those at TSD facilities), see Hazardous Waste Operations.


Helicopters

All electrically operated cargo hooks on helicopters must have the activating device properly designed and installed. The employer must make sure that hooks are tested daily by a competent person to verify that the release works properly.

29 CFR 1910.183(d)


Laundry Machinery and Operations

Laundry workers must be instructed about hazards and safe work practices. Instruction can include bulletins, printed rules, and verbal instructions.

29 CFR 1910.264(d)(1)(v)

Workers who decontaminate protective clothing or equipment at commercial laundries or cleaners must be informed about harmful effects of exposure to hazardous substances.

29 CFR 1910.120(k)(7)


Lead

Every employer that has a workplace with potential exposure to airborne lead at any level must inform employees of the contents of Appendices A and B to 29 CFR 1910.1025.

29 CFR 1910.1025(l)(1)(i)

Employers must train all workers exposed to actionable levels of lead or to lead compounds (30 micrograms of lead per cubic meter of air; 30 µg/m3) or to levels that may possibly cause skin or eye irritation. The training must be done before the time of initial job assignment and at least annually thereafter. Training must cover all of the following:

•	the lead standard (and its appendices) for general industry

•	operations that could result in exposure to lead above the action level

•	the purpose, selection, fitting, and use of respirators

•	medical surveillance and medical removal protection programs

•	engineering controls and work practices

•	any compliance plan in effect

•	the prohibition on removing lead with chemical agents except under the direction of a licensed physician

29 CFR 1910.1025(l)(1)

Lead is also discussed in the digest topic, Lead.


Liquefied Petroleum (LP) Gases

Persons whose work involves installing, removing, operating, and maintaining LP gas must be properly trained.

29 CFR 1910.110(b)(16)

Standard watch service must include LP gas installations; attending personnel must be appropriately trained.

29 CFR 1910.110(d)(12)(i)


Materials Handling and Storage

The employer must have a training program for workers who service rim wheels. The program must describe work hazards and safety procedures. Employers must evaluate workers' ability to service rim wheels and to perform a number of specific tasks. Employers must provide additional training if workers lack proficiency.

29 CFR 1910.177(c)

Only trained, authorized workers are permitted to operate a powered industrial vehicle (see the digest topic, Forklift Operations).

29 CFR 1910.178(l)


Mechanical Power Presses

Employers must make sure:

•	that trained personnel inspect and maintain power presses; and

•	that operators follow correct operating procedures.

Workers must have training before they begin work and at least annually thereafter.

29 CFR 1910.217(e)(3), (f)(2), and (h)(13)

PSDI Mode Training

Workers who use presses in the presence-sensing device initiation (PSDI) mode must have training that covers the following:

•	the manufacturer's recommended test procedures for checking the presence-sensing device and using the test rod

•	required safety distances

•	operation, function, and performance of the PSDI mode

•	requirements for hand tools used in the PSDI mode

•	severe consequences that can result from attempting to override the safeguard functions of the PSDI system

29 CFR 1910.217(h)(13)

Certification

The employer must:

•	certify in writing that a worker is trained when training is finished;

•	document the worker's name, trainer's signature, and training date; and

•	maintain the certificate on file for the duration of a worker's employment.

29 CFR 1910.217(h)(13)(ii)

Mechanical power presses are also discussed in the digest topic, Mechanical Power Presses.


Medical Services and First Aid

First aid must be available from trained personnel on-site unless an infirmary, clinic, or hospital is "in near proximity" to the workplace. Qualified first aid personnel must have a current first aid card documenting training from the American Red Cross or an equivalent provider.

29 CFR 1910.151

Medical services and first aid are discussed in the digest topic, Medical Services and First Aid.


Noise Protection

Workers exposed to an 8-hour time-weighted average (TWA) in excess of 90 decibels must wear hearing protectors (see Noise Exposure). Workers who are exposed to an 8-hour TWA of 85 decibels or above have the option of wearing employer-provided hearing protectors, but do not have to wear them.

The employer must:

•	allow covered employees to choose from a variety of suitable hearing protectors; and

•	teach workers how to use and to care for them.

29 CFR 1910.95(g)(8)(ii)(A)

Training Program

For workers exposed to noise at or above an 8-hour TWA of 85 decibels, employers are also required to develop an effective hearing conservation program (see Noise Exposure). As part of the program, employers must inform each affected employee of:

•	the effects of noise on hearing

•	the advantages and disadvantages of hearing protectors

•	instructions on the use, care, fitting, and selection of hearing protectors

•	an explanation of audiometric testing and procedures

29 CFR 1910.95(k)


Personal Protective Equipment (PPE)

The employer must provide training to each employee who uses personal protective equipment (PPE). Each employee must be trained to know all of the following:

•	when PPE is necessary

•	what PPE is necessary

•	how to properly put on, remove, adjust, and wear PPE

•	the useful life and limitations of PPE

•	the proper care, maintenance, and disposal of PPE

29 CFR 1910.132(f)

Certification

The employer must certify in writing that each affected employee receives and understands the required training through a written certification. The certification must contain the name of each employee trained, the dates of training, and the subject of the certification.

29 CFR 1910.132(f)(4)

Personal protective equipment is discussed in the digest topic, Personal Protective Equipment (PPE). A sample plan for selecting PPE through a required hazard assessment is provided in Sample Hazard Assessment Plan.


Powered Platforms

Powered platforms must be operated only by persons who have been trained by a "competent person" in all of the following:

•	recognizing and preventing powered platform hazards in general

•	recognizing and preventing hazards associated with:

-	each worker's particular tasks

-	the particular work platform

•	required Emergency Action Plan procedures for the work platform

•	work procedures for operating and inspecting working platforms

•	inspection, care, and use of personal fall-arrest systems

29 CFR 1910.66(i)(1)

Emergency Planning

There must be a written Emergency Action Plan (see Sample Emergency Action Plan) for each working platform. The plan must explain emergency procedures, escape routes, and alarms. The employer must review the plan with workers before they use the platform and whenever the plan is changed.

29 CFR 1910.66(e)(9)

Certification

The employer must:

•	certify in writing that workers have been trained to operate and inspect powered platforms;

•	include the trainee's name, trainer's signature, and training date; and

•	maintain the certification record for the duration of the worker's employment.

29 CFR 1910.66(i)(1)(v)

Aerial Lifts

Only trained persons are permitted to operate an aerial lift.

29 CFR 1910.67(c)(2)(ii)


Process Safety Management of Highly Hazardous Chemicals

All workers involved in manufacturing or developing over 100 specific highly hazardous chemicals must be trained in the hazards, emergency operations, and safe work practices applicable to their job tasks. In addition, workers must have refresher training at least every three years to assure that their understanding of operating procedures remains current.

29 CFR 1910.119(g)

The employer must provide a written certification to show that workers understand their training. Documentation must include the worker's name, training date, and means used to verify the employee's understanding.

29 CFR 1910.119(g)

Process safety management is also discussed in the digest topic, Process Safety Management of Highly Hazardous Chemicals.


Respiratory Protection

Under OSHA's Respiratory Protection Standard, employers must make sure that employees who use respirators are first effectively trained in their use. The training must be comprehensive and understandable. Retraining must take place at least annually.

Training must cover all of the following:

•	the need for respirators and importance of their proper use and fitting

•	the limitations and capabilities of respirators

•	effective use of respirators during malfunctions and emergencies

•	inspecting, wearing, and removing respirators

•	checking the seal on respirators

•	procedures for respirator storage and maintenance

•	recognizing medical signs and symptoms that impair respirator effectiveness

•	general requirements of the OSHA standard

29 CFR 1910.134

"Portability" of Training

An employer is not required to repeat training if an employee has been trained within the last 12 months and can demonstrate the necessary knowledge to properly use his or her respirator. However, if an employee lacks skill or knowledge in particular areas, the employer must provide training in those areas. Previous training that is not repeated initially must be provided no later than 12 months from the date of previous training.

Repair Work

Respirator replacements or repairs must be done only by experienced, appropriately trained persons.

29 CFR 1910.134(h)(4)

Respiratory protection is discussed in the digest topic, Respiratory Protection. A sample Respiratory Protection Plan is available from Summers Press in its Sample Safety Plans on CD.


Slings

Before use, sling fastenings and attachments must be inspected every day for damage or defects by a competent person designated by the employer. Damaged or defective slings must be immediately removed from service.

29 CFR 1910.184(d)


Tank Storage (Floods)

Facilities in flood-prone areas that store flammable or combustible liquids in tanks must post flood emergency procedures.

29 CFR 1910.106(b)(5)(vi)(v)(2)

Station operators who carry out the procedures must know the location and operation of valves and equipment.

29 CFR 1910.106(b)(5)(vi)(v)(3)

Flammable liquids are discussed in the digest topic, Flammable Liquids.


Tanks, Open-Surface

Persons who work in and around open-surface tanks must be informed about:

•	potential job hazards; and

•	personal protection and first aid procedures for any job hazards.

29 CFR 1910.94(d)(9)

In emergencies involving open-surface tanks, workers who are in contaminated or oxygen-deficient air must wear respirators or have an adequate oxygen supply. An industrial hygienist or other qualified person must select the respirators from those approved by the U.S. Bureau of Mines. Workers who wear the respirators must be trained to use them correctly.

29 CFR 1910.94(d)(9)(vi)

If workers enter a tank that contains a hazardous atmosphere during an emergency, at least one trained standby person who is equipped with a respirator must be present in the nearest uncontaminated area.

29 CFR 1910.94(d)(11)(v)

Open-surface tanks are also discussed in the digest topic, Tanks, Open-Surface.


Telecommunications

Workers must be trained in safe telecommunications work practices before they begin work. Training can be on the job, in the classroom, or a combination of both. Employers do not have to provide training for workers who have been appropriately trained before their employment.

Telecommunications training must cover:

•	recognizing and avoiding hazards related to harmful substances and animals, insects, and plant life;

•	emergency procedures; and

•	first aid, including artificial respiration.

29 CFR 1910.269(c)

Certification

On the completion of training, the employer must document the worker's name, the trainer's signature, and the training date. The certification record must be maintained for the duration of the worker's employment and be made available to OSHA on request.

29 CFR 1910.269(c)

Storage Batteries

Persons who work with storage batteries must be instructed in emergency procedures, such as dealing with acid spills.

29 CFR 1910.269(b)(2)

Derricks

Manufacturer's specifications, load ratings, and instructions for operating derricks must be strictly observed. Rated load capacities and instructions for derrick operation must be posted on a permanent weather-resistant plate on the derrick so that the operator can see it. The employer must make sure that operators are properly trained. Derricks must be inspected by a competent person at least once a year.

29 CFR 1910.268(j)(4)(iv)(D)

High Voltage Work

Workers who use high voltage to locate trouble or test cables must be instructed in precautions for their own safety and for the safety of co-workers.

29 CFR 1910.268(1)(1)

Manholes

A person trained in first aid must be immediately available to assist a worker in a manhole who encounters a hazard.

29 CFR 1910.268(o)(1)(ii)


Welding, Cutting, and Brazing

Cutters, welders, and their supervisors must be trained to perform their jobs and to operate their equipment safely.

29 CFR 1910.252(a)(2)(xiii)(c)

Arc welding equipment operators must be trained in all of the following:

•	fire prevention and protection

•	protection of personnel

•	health protection and ventilation

•	removing electrodes and making sure that electrode holders do not contact workers or conducting objects

•	opening the power supply switch to the equipment:

-	when an arc welder or cutter leaves the area; or

-	when the welding or cutting machine is moved

•	reporting any faulty or defective equipment to the supervisor

•	not dipping hot electrode holders in water

29 CFR 1910.254(d)

When regulators or parts of regulators (including gauges) need repairs, the work must be performed by trained, skilled mechanics.

29 CFR 1910.253(6)(ii)

Using Fuel Gas

Workers in charge of the oxygen or fuel-gas supply must:

•	have training to use fuel gas safely;

•	have operation and maintenance instructions readily available; and

•	be judged competent by the employer before having this responsibility.

29 CFR 1910.253(a)(4)

Fire Watchers

Welding or cutting work requires at least one fire watcher if:

•	performed in a location in which more than a minor fire may develop; or

•	other specific circumstances pose a distinct fire danger.

Fire watchers must be instructed on how to sound an alarm and on how to use fire-fighting equipment.

29 CFR 1910.252(a)(2)(iii)(B)

Welding is discussed in the digest topics, Welding and Welding - Confined Spaces. Cylinders of compressed gas used in welding are discussed in the digest topic, Welding - Compressed Gas Cylinders.


Woodworking Machinery

Sharpening or tensioning saw blades or cutters must be done only by persons who have demonstrated the necessary skill for those tasks.

29 CFR 1910.213(s)(5)

Woodworking machinery is discussed in the digest topic, Woodworking Machinery.


Table of Contents

State OSHA Plans

Introduction

States with OSHA-Approved Plans

State and Federal Standards

State Administration and Enforcement

State Recordkeeping/Reporting Requirements

Major State Standards


Introduction

State OSHA Plans

The federal Occupational Safety and Health Act generally replaces state laws regulating workplace safety. However, Congress provided a mechanism by which states could continue to play a major role in the workplace safety arena. By having their safety plans certified and approved by OSHA, states can retain primary responsibility for enforcing safety in the workplace. Over 20 states have taken advantage of this option.

This chapter provides a general overview of the rules and practices in states with OSHA-approved plans. However, the information is not intended as a substitute for an in-depth evaluation of any individual state. An employer located in a state with an OSHA-approved plan should contact its state agency to pinpoint specific standards in which the employer is interested, to determine if any particular standard applies to the employer, and to ensure complete compliance with a state's specific standards.


States with OSHA-Approved Plans

Currently, the following states have OSHA-approved plans that apply to private employers:

•	Alaska	•	Maryland	•	South Carolina

•	Arizona	•	Michigan	•	Tennessee

•	California	•	Minnesota	•	Utah

•	Hawaii	•	Nevada	•	Vermont

•	Indiana	•	New Mexico	•	Virginia

•	Iowa	•	North Carolina	•	Washington

•	Kentucky	•	Oregon	•	Wyoming

Although federal OSHA does not apply to public employees, most state plans do. In addition, three states (Connecticut, New Jersey, and New York) have OSHA-approved plans that apply exclusively to public employees.

A listing of contact agencies for states with OSHA-approved plans is included in Chapter 9.


State and Federal Standards

To gain OSHA's approval, states must enforce standards that are "at least as effective as" the federal rules. Basically, this means that states with approved plans can have standards that are stricter than OSHA's, but not less strict. In addition, states must modify their own standards to keep current with federal changes. Whenever federal OSHA adopts a new standard, states must adopt a comparable standard within six months.

Generally speaking, states with OSHA-approved plans closely track the federal rules with relatively minor variations. However, several states, such as California, Michigan, Oregon, and Washington, diverge widely from the federal provisions. The chart in Major State Standards highlights some areas in which states with approved plans may differ from applicable federal standards. It also identifies some unique state standards of special interest that have no federal equivalents.


State Administration and Enforcement

In addition to enforcing effective safety standards, states must satisfy certain procedural requirements to obtain OSHA's approval. Although the exact particulars vary, each state must meet the following basic requirements:

•	an effective inspection program for enforcing safety standards

•	a fair procedure to grant variances and to issue temporary standards

•	a system at least as effective as federal OSHA's for injury reporting and recordkeeping (individual state differences are charted in State Recordkeeping/Reporting Requirements)

•	a system for responding to employee complaints of workplace hazards and for protecting complaining workers from any discrimination

•	a program for promptly issuing citations and notifying employers and employees of the violation of any standard

•	an opportunity for cited employers to obtain a full and fair hearing to contest alleged violations


State Recordkeeping/Reporting Requirements

States with OSHA-approved plans may have recordkeeping and accident reporting requirements different from federal OSHA's as long as they are "at least as effective." Several states differ from federal OSHA in:

•	the recordkeeping exemptions for retail employers in certain SIC codes (Partially Exempt Businesses)

•	the "trigger point" for accident reporting requirements (Accident Reporting Requirements)

The following chart discusses recordkeeping exemptions and accident reporting requirements in states with OSHA-approved plans. Exempt employers under state plans (as with federal OSHA) must nevertheless comply with accident reporting requirements, surveys from the Bureau of Labor Statistics, posting requirements, and OSHA safety regulations. Employers should also remember that most states have additional accident reporting requirements under their workers' compensation laws that are not addressed in the following chart.

Nearly all states with OSHA-approved plans have changed their recordkeeping rules in response to the federal overhaul that took effect on January 1, 2002 (see Overview of Recordkeeping Requirements). In addition, most states have revised their reporting requirements to exclude certain public transportation and motor vehicle accidents (see Accident Reporting Requirements).

Alaska

•	Recordkeeping exemptions: Same as the new federal OSHA rule.

•	Reporting: Must immediately report (no later than eight hours) any work-related accident that results in one or more fatalities or one or more inpatient hospitalizations. Alaska has not adopted the revision to the federal OSHA rule that excludes some public transportation and motor vehicle accidents from the reporting requirements. (Alaska Stat. § 18.60.058)

Arizona

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.

California

•	Recordkeeping exemptions: Same as the new federal rule, except for a few retail SIC code exemptions. Unlike federal OSHA, Cal/OSHA does not recognize a blanket exemption for SIC Code 78 (Motion Picture). Rather, exemptions apply only to SIC Codes 782 (Motion Picture Distribution and Allied Services), 783 (Motion Picture Services), and 784 (Video Tape Rental).

•	Reporting: Must immediately report (no later than eight hours) any work-related fatality or any one or more "serious injuries" (defined as requiring 24 or more hours of hospitalization or involving any degree of permanent disfigurement or any loss of a member). California has not adopted the revision to the federal OSHA rule excluding some public transportation and motor vehicle accidents from the reporting requirements. (Cal. Lab. Code § 6409.1)

Hawaii

•	Recordkeeping exemptions: Same as federal OSHA, except for a few SIC code exemptions. Hawaii does not recognize an exemption for hardware stores (SIC Code 525) or for offices and clinics of medical doctors and dentists (SIC Codes 801, 802, 803, 804, 807, and 809).

•	Reporting: Must immediately report (no later than eight hours) any work-related accident that results in the loss of life, hospitalization of three or more employees, or property damage over $25,000. Hawaii has adopted the revision to the federal OSHA rule excluding some public transportation and motor vehicle accidents from the reporting requirements. (HAR § 12-52-8)

Indiana

•	Recordkeeping exemptions: Same as old federal rule. However, Indiana is in the process of adopting the new federal rule and already allows employers the option of using the new federal 300 and 301 Forms to comply with recordkeeping requirements.

•	Reporting: Same as unrevised federal rule. However, Indiana is in the process of adopting the revision to the federal OSHA rule that excludes some public transportation and motor vehicle accidents from the reporting requirements.

Iowa

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.

Kentucky

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.

Maryland

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.

Michigan

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.

Minnesota

•	Recordkeeping exemptions: Same as new federal rule, except Minnesota has no exemption for retail industry SICs.

•	Reporting: Same as revised federal rule.

Nevada

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.

New Mexico

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.

North Carolina

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule. In addition, if the employer misses the eight-hour deadline, it must report any fatality to the sate police.

Oregon

•	Recordkeeping exemptions: Same as new federal rule. (OAR § 437-001-0700)

•	Reporting: Must immediately report (no later than eight hours) any work-related accident that results in a fatality or hospitalization of three or more workers. Must report within 24 hours any hospital admission and medical treatment of a single worker. However, injuries do not have to be reported if they arise from motor vehicle accidents that happen on public streets or highways. (OAR § 437-001-0700)

South Carolina

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.

Tennessee

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.

Utah

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Must report within 12 hours any work-related accident that results in a fatality or any one or more disabling or serious injuries to workers. (UAC § 614-1-5) (Note: federal OSHA requires state rules to be "at least as effective" and requires notification in no more than eight hours.)

Vermont

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.

Virginia

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.

Washington

•	Recordkeeping exemptions: Same as new federal rule, except Washington does not recognize an exemption for offices and clinics of medical doctors and dentists (SIC Codes 801, 802, 803, 804, 807, and 809). (WAC § 296-27-0101 et seq.)

•	Reporting: Must report within eight hours any work-related accident that results in a fatality or probable fatality or in the hospitalization of two or more workers. (WAC § 296-27-0101 et seq.)

Wyoming

•	Recordkeeping exemptions: Same as new federal rule.

•	Reporting: Same as revised federal rule.


Major State Standards

The following listing highlights differences and unique provisions for general industry employers in states with OSHA-approved plans. The list provides only a "thumbnail sketch" for each covered state and is not intended to provide complete and thorough information on the practices of any individual state. Regardless of how closely a particular state's plan follows federal OSHA, an employer located in a state with an OSHA-approved plan should contact its state agency to pinpoint specific standards in which it is interested, to check the currency and applicability of any particular standard, and to ensure complete compliance with a state's specific standards.

Alaska

•	General Industry Differences

-	air contaminants (1989 federal standard in Table Z-1A) (8 AAC 61.1100)

-	asbestos abatement certification and training (8 AAC 61.600 et seq.)

-	electrical power generation, transmission, and distribution (8 AAC 61.1080)

-	electrical safety-related work practices (8 AAC 61.1090)

-	explosives and blasting (8 AAC 61.1020)

-	logging (8 AAC 61.1060)

-	permit-required confined spaces (8 AAC 61.1050)

-	respiratory protection (8 AAC 61.1030)

-	telecommunications (8 AAC 61.1070)

-	temporary labor camps (8 AAC 61.1040)

•	Unique State Standards

-	petroleum drilling and production (8 AAC 61.1180)

-	petroleum refining, transportation, and handling (8 AAC 61.1060)

-	physical agent data sheet (cold and heat stress, ionizing radiation, lasers, and microwave radiation): required posting as part of hazard communication standard (8 AAC 61.1110)

-	special certification and training for (1) asbestos abatement workers, (2) explosives handlers, and (3) painters who work with hazardous materials (8 AAC 61.620-61.1020)

Arizona

•	General Industry Differences

-	prohibition on the use of hoes with handles under four feet for weeding or thinning crops (AAC R20-5-605)

•	Unique State Standards

-	special field sanitation rule applicable to agricultural establishments (AAC R20-5-670)

California

•	General Industry Differences

California's general industry safety rules differ in many respects from the applicable federal standards. An employer may contact the California Division of Occupational Safety and Health (DOSH) for further information.

•	Unique State Standards

-	asbestos work: advance registration required for work involving 100 square feet or more of asbestos-containing construction material that could be released (Cal. Lab. Code § 6501.5)

-	ergonomics program: required under certain circumstances (8 CCR § 5110)

-	field sanitation circumstances (8 CCR § 3457)

-	fines and penalties: increased civil and criminal fines and penalties for violations of safety standards (Cal. Lab. Code § 6304.5 et seq.)

-	injury and illness prevention (IIP) program: mandatory for all employers (Cal. Lab. Code § 6401.7; 8 CCR § 3203)

-	permits: required in advance for especially dangerous work, including (1) trench construction or excavation deeper than five feet, (2) construction or demolition of structures or scaffolds three stories or higher, (3) use of underground diesel engines in mines and tunnels, and (4) tower cranes (annual permits available for tower cranes in motion pictures, television, or the theater) (8 CCR §§ 341; 341.1)

-	regulated carcinogens: special rules applicable (Cal. Lab. Code § 9000 et seq.)

-	smoking: general prohibition in enclosed workplaces (Cal. Lab. Code § 6404.5)

-	toxic chemicals: required Proposition 65 warnings (Cal. Health & Safety Code § 25249.5)

-	workplace security: special guidelines apply, as well as special laws to provide for the protection of employees from workplace violence and the compensation of victims (Cal. Civ. Proc. Code § 527.8; Cal. Lab. Code § 3553)

[Summers Press publishes a special edition of its OSHA compliance guide, the California OSHA Compliance Guide, that contains additional information on Cal/OSHA's unique requirements and general industry standards. An employer may also contact the California Division of Occupational Safety and Health (DOSH) for further information.]

Hawaii

•	General Industry Differences

Despite differences, Hawaii's general industry standards are substantially similar to those used by federal OSHA. In addition, Hawaii is in the process of incorporating the federal standards into its state safety regulations. Once this process is complete, Hawaii's standards are expected to be even closer to those of federal OSHA.

•	Unique State Standards

-	daily inspections required for all general contractors on projects with 30 or more workers

-	forklift work platform specifications (HAR 12-130-5)

-	safety program: required for any employer that has 25 or more employees, or any construction industry employer awarded a state contract of $100,000 or more

-	tree or brush cutting, trimming, or removal, including near power lines or power facilities

-	window cleaning

-	work platforms suspended from cranes: require prior approval (HAR 12-130-9)

Indiana

•	General Industry Differences

None significant.

•	Unique State Standards

None significant.

Iowa

•	General Industry Differences

-	expansion of Iowa's right-to-know law to the public and emergency response personnel (Iowa Code Ann. § 89B.1 et seq.; Iowa Admin. Code r. 347-110.1 et seq.)

•	Unique State Standards

-	protective clothing and equipment for local government firefighters (Iowa Admin. Code r. 347-27)

-	railway sanitation regulations (Iowa Admin. Code r. 347-29.1 et seq.)

Kentucky

•	General Industry Differences

-	asbestos (803 KAR 2:320)

-	bloodborne pathogens (803 KAR 2:320)

-	carcinogens (803 KAR 2:320)

-	compressed gases (803 KAR 2:307)

-	firefighters (803 KAR 2:311)

-	first aid (803 KAR 2:310)

-	flammables and combustible liquids (803 KAR 2:307)

-	floor and wall hole and opening guards (803 (KAR 2:302)

-	lock-out/tag-out (803 KAR 2:309) (Lock-out required instead of tag-out wherever possible; tags must be attached where the lock-out device would have been.)

-	mechanical power presses (803 KAR 2:314)

-	medical records access (803 KAR 2:302)

-	medical services and first aid (803 KAR 2:309)

-	noise protection (803 KAR 2:306)

-	respiratory protection (803 KAR 2:308)

•	Unique State Standards

-	battery charging, installation, and removal (803 KAR 2015, § 1)

-	electrical testing (803 KAR 2015, § 2)

-	fire apparatus (803 KAR 2015, § 6)

-	handling bulk hazardous liquids (803 KAR 2019)

-	off-highway vehicles and equipment (803 KAR 2015, § 4)

-	refuse collection and compaction equipment (803 KAR 2018)

-	rollover and overhead protection (803 KAR 2015, § 5)

-	safety belts, lanyards, and lifelines (803 KAR 2015, § 3)

-	toxic substances (803 KAR 2:062)

Maryland

•	General Industry Differences

-	field sanitation standards (COMAR .09.12.36)

-	hazard communication: requires preparation of a single chemical information list, includes wood products, covers fire and rescue personnel, and contains other differences (COMAR .09.12.33)

-	personnel platforms suspended from cranes and derricks (COMAR .09.12.38)

•	Unique State Standards

-	asbestos: protective clothing (Md. Lab. & Empl. Code Ann. § 5-601)

-	confined spaces: requires notice from subcontractors for maintenance work in confined spaces and limits use of part-time and temporary help (Md. Lab. & Empl. Code Ann. § 5-602)

-	high voltage lines: prohibits anyone from working within 10 feet of lines with more than 750 volts without effective guarding by physical barriers, deenergizing, etc. (Md. Lab. & Empl. Code Ann. § 6-101)

-	manhole work: generally requires a standby employee for emergencies (Md. Lab. & Empl. Code Ann. § 5-603)

-	sanitary sewer lines (Md. Lab. & Empl. Code Ann. § 5-606)

-	smoking: prohibited in enclosed workplaces (COMAR .09.12.23)

Michigan

•	General Industry Differences

While Michigan generally follows the federal standards, there are many areas in which its state standards differ. An employer should contact Michigan OSHA (MIOSHA) for further information and to pinpoint particular differences.

•	Unique State Standards

There are a number of areas in which Michigan has unique additional state standards. An employer should contact MIOSHA for further information and to pinpoint particular differences.

Minnesota

•	General Industry Differences

-	abatement verification (Minn. R. 5210.0532)

-	confined spaces (Minn. R. 5205.1000 - .1040)

-	cranes and hoists (Minn. R. 5205.1200 - .1230)

-	elevators, dumbwaiters, escalators, and moving walks (Minn. R. 5205.0400 - .0490)

-	environmental controls: submission of control measures, vent-pipe outlets, indoor workroom ventilation and temperature, and gas-fired machines and appliances (Minn. R. 5205.0100 - .0115)

-	hazard communication: differs in several respects, including requirement for information on infectious and harmful physical agents (Minn. R. 5206.0100 et seq.)

-	hoppers (Minn. R. 5205.1400)

-	illumination: minimum levels, diffusion and differentiation, exit and emergency lighting, and illumination levels (Minn. R. 5205.0120 - 5205.0200)

-	machine guarding: pneumatic power tools, machines with revolving parts, machine controls and equipment, foot-actuated machines, and hydraulic presses (Minn. R. 5205.0850 - .0890)

-	maintenance and repair of buildings and equipment (Minn. R. 5205.0650 - .0675)

-	mobile earth-moving equipment: required training and high-visibility PPE (Minn. R. 5207.1000)

-	permissible exposure limits (PELs) (Minn. R. 5205.1010)

-	personal protective equipment (PPE): head protection and high visibility PPE (Minn. R. 5205.0020 - .0030)

-	personnel platforms suspended from cranes and derricks (Minn. R. 5205.01230 - .1300)

-	platform manlifts (Minn. R. 5205.0550 - .0590)

-	ships ladders (Minn. R. 5205.0050 - .0060)

-	steam boilers (Minn. R. 5205.0330)

-	suspension scaffolds (Minn. R. 5205.0065)

-	vehicles (Minn. R. 5205.0750 - .0770)

-	ventilation for garages (Minn. R. 5205.0200)

-	walking/working surfaces (Minn. R. 5205.0040)

-	wells, pits, shafts, and similar places (Minn. R. 5205.0080)

•	Unique State Standards

-	accident and injury reduction program: required for employers within designated standard industrial classifications (Minn. Stat. Ann. § 182.653; Minn. R. 5205.1500)

-	carbon monoxide monitoring for both general industry and construction employers (Minn. R. 5205.0116)

Nevada

•	General Industry Differences

None significant.

•	Unique State Standards

-	ammonium perchlorate: special standards applicable to training and safety for this explosive (NAC 618.5155 et seq.)

-	asbestos abatement work: required licensing and training (Nev. Stat. Ann. § 618.759 et seq.)

-	construction projects: require registration and possible safety plan review they if involve a structure: (1) with a floor level more than 30 feet above or below ground, (2) with an initial construction cost of at least $10 million, (3) that will be over 50,000 square feet on completion, or (4) that will be more than 60 feet high on completion (excluding any antenna, smokestack, or flagpole) (NAC § 618.494 et seq.)

-	cranes: require a certificate of competency from a trainer before operating a tower crane or a crane used to erect or dismantle a tower crane (NAC § 618.356 et seq.)

-	elevator or personnel hoist: required to transport workers constructing a structure more than 60 feet above ground level or 48 feet below ground (NAC 618.507)

-	safety committee: required for employers with 25 or more employees (Nev. Stat. Ann. § 618.383)

-	safety program: written program required for employers with more than 10 employees (the program requirement for employers with 10 or fewer employees and excessive losses is scheduled to expire on July 1, 1999) (Nev. Stat. Ann. § 618.383)

-	toilet facilities: separate male and female facilities required for five or more male employees and three or more female employees on the same premises (Nev. Stat. Ann. § 618.720)

New Mexico

•	General Industry Differences

-	field sanitation standards (11 NMAC 5.4.11)

-	firefighting standards: applicable to public fire departments staffed with non-volunteers (11 NMAC 5.2.10)

-	hazard communication standard: differs in documentation of training requirements and MSDS access for employers with more than one geographical location (NMAC 5.2.9; 5.3.9)

-	short-handled hoes and knives: prohibited for vegetable crops (11 NMAC 5.2.10)

•	Unique State Standards

See above.

North Carolina

•	General Industry Differences

-	air contaminants: different permissible exposure limits (PELs) for certain contaminants (13 NCAC 07F.0101(a)(4)(A))

-	electric power generation: specifies criteria for when free climbing may be allowed (13 NCAC 07F.0101(a)(3))

-	hazardous substances: clarification of definition (13 NCAC 07F.0101 (a)(4)(B))

-	hazardous waste operations and emergency response: additional training for individuals who respond to certain hydrocarbon fuel tank leaks (13 NCAC 07F.0101(a)(1))

-	personal protective equipment: further defines an employer's responsibility (13 NCAC 07F.0101(a))

•	Unique State Standards

-	fire safety: 1991 edition of ANSI/NFPA 101, Code for Safety to Life from Fires in Buildings and Structures, applicable to all places of employment (13 NCAC 07F.0102)

-	overhead high-voltage line safety: North Carolina has a special law that regulates this subject (N.C. Gen. Stat. § 95-229 et seq.)

-	safety program: required for employers with workers' compensation modifier of 1.5 or higher (safety committee also required for those with 11 or more employees) (N.C. Gen. Stat. § 95-251)

-	structural steel and steel plate: special ANSI standards (13 NCAC 07F.0401 et seq.)

Oregon

•	General Industry Differences

While Oregon generally follows the federal standards, there are a number of areas in which its standards differ from those contained in federal OSHA. An employer should contact Oregon OSHA for further information and to pinpoint particular differences.

•	Unique State Standards

There are many areas in which Oregon has unique additional state standards. An employer should contact Oregon OSHA for further information on unique additional standards. Of particular concern, however, may be the requirement that an employer establish a safety committee if:

-	it has more than 10 employees; or

-	it has a lost workday incidence rate within the top 10% in its industry or within the top 25% of workers' compensation premium classifications. (Or. Rev. Stat. §§ 654.176; 654.182)

In 1999, Oregon enacted several laws that affect the occupational safety area. One bill requires Oregon OSHA to focus its inspection efforts on problem worksites. Another law applies an audit privilege to employers that conduct their own workplace safety and health safety audits through use of a private consultant. In addition, in 1999 Oregon OSHA adopted additional rules for forklifts that supplement the requirements of the federal OSHA standards.

South Carolina

•	General Industry Differences

-	dip tanks: requirements concerning ignition sources near combustibles (S.C. Code Regs. 71, Art. 1, Subpart 6)

-	electrical wiring and equipment: requirements in spraying areas (S.C. Code Regs. 71, Art. 1, Subpart 6)

-	"nationally recognized testing laboratory" definition (S.C. Code Regs. 71, Art. 1, Subpart 6)

•	Unique State Standards

None significant.

Tennessee

•	General Industry Differences

-	air contaminants: retention of the 1989 version of the federal permissible exposure limits (PELs)

-	lavatories: table specifying the number of lavatories required for sanitation (29 CFR 1910.141(d)(2); Tennessee Department of Labor Rule 0800-1-1-.141(d)2.(i))

-	radiation: stricter reporting requirements to complement state's stricter radiological regulations (29 CFR 1910.96(b)(5); 39 Fed. Reg. 23598)

-	right-to-know law: state law differs in some respects from the federal standard (e.g., requires annual refresher training of employees, filing of chemicals list with Commissioner, and obtaining of MSDS sheets within specified periods after their request by the employee) (Tenn. Code. Ann. § 50-3-2001 et seq.)

-	wire-rope slings: prohibition on using knots or wire rope clips to form eyes (29 CFR 1910.184; 40 Fed. Reg. 27287)

•	Unique State Standards

None significant.

Utah

•	General Industry Differences

-	conveyors (UAC R614-5-2)

-	crawler, locomotive, and truck cranes (UAC R614-5-1)

-	explosives and blasting: special rules (UAC R614-2-13; R614-4-4)

-	personal protective equipment (PPE) (UAC R614-1-6)

•	Unique State Standards

-	crushing and grinding equipment (UAC R614-6-1)

-	elevators and personnel hoists (UAC R614-3-3)

-	filters and centrifuges (UAC R614-6-9)

-	flammable solids (UAC R614-4-1)

-	food processing (UAC R614-6-10)

-	hot metallurgical operations (UAC R614-6-7)

-	industrial in-house railroads (UAC R614-6-4)

-	livestock butchering and bulk carcass handling (UAC R614-6-5)

-	moving houses and buildings (UAC R614-6-3)

-	oil, gas, and geothermal drilling (UAC R614-2-8)

-	transportation of workers (UAC R614-6-6)

-	window cleaning (UAC R614-6-2)

Vermont

•	General Industry Differences

-	air contaminants: retention of the 1989 OSHA permissible exposure limits (PELs) (29 CFR 1910.1000)

-	"two lineworker" rule: generally requires two lineworkers trained in CPR, first aid, and pole rescue procedures for work on energized conductors of more than 600 volts (CVR 24-050-001)

•	Unique State Standards

-	smoking in workplace: prohibition or restriction to designated areas (Vt. Stat. Ann. tit. 18, § 1421 et seq.)

Virginia

•	General Industry Differences

-	Confined Space Standard for the Telecommunications Industry (16 VAC 25-70-10 et seq.)

•	Unique State Standards

-	Overhead High Voltage Safety Act: (1) provides rules for protecting workers near overhead high-voltage lines, and (2) requires certain warning signs, notifications, and other precautions. (Va. Code Ann. § 59.1-406 et seq.)

Washington

•	General Industry Differences

While Washington generally follows the federal standards, there are a number of areas in which its standards differ from those contained in federal OSHA. An employer should contact the Washington Industrial Safety and Health Administration (WISHA) for further information and to pinpoint particular differences.

•	Unique State Standards

There are many areas in which Washington has unique state standards. An employer should contact WISHA for further information and to pinpoint particular differences. However, some of the areas in which additional requirements apply are as follows:

-	accident prevention programs: written program required for all employers (WAC 296-24-020)

-	ergonomics: all employers with employees who work in "caution zone jobs" are covered by the new rule; required implementation dates to complete hazard analysis vary from July 1, 2002 (July 1, 2003 for actual hazard reduction) for all employers with 50 or more employers in designated high hazard SIC Codes to July 1, 2005 (July 1, 2006 for actual hazard reduction) for employers with 10 or fewer full-time employees. In addition, a directive from Governor Locke has delayed the imposition of any penalties under the rule for two years after each effective date in the timeline. (WAC 296-62-051)

-	first aid training and certification: required unless the worksite is within a two-minute response time of an aid car, medic unit, or established ambulance service with first aid-trained attendants (WAC 296-56-60060)

-	late-night retail establishments: special standards to prevent crime for those doing business (except restaurants and hotels) between 11 p.m. and 6 a.m. (Wash. Rev. Code Ann. § 49.22.010 et seq. )

-	safety bulletin board: required for employers with eight or more employees (WAC 296-24-055)

-	safety committees: generally required for employers with 11 or more employees (regular safety meetings required for employers with fewer employees) (WAC 296-24-045)

-	special standards: applicable to ski area operations, firefighter activities, and tobacco smoke in offices (WAC 296-59-001 et seq.; 296-62-12000; 296-305-01001 et seq.)

-	training: additional requirements applicable to powered material handling equipment, toxic materials, machine tools, and utility system operations (WAC 296-24-020)

Wyoming

•	General Industry Differences

-	laundering and dry cleaning (WCWR 025-125-001)

•	Unique State Standards

 -	oil and gas well drilling and oil and gas well servicing (WCWR 025-126-001 et seq.; WCWR 025-127-001 et seq.)

-	wood processing (WCWR 025-129-001 et seq.)


Table of Contents

Directories

Introduction

Abbreviations

States with Approved Plans

OSHA Regional and Area Offices

OSHA/State Consultation Project Directory

OSHA Internet Site


Introduction

Directories

This chapter provides employers with the following:

•	a list of important abbreviations used in this book

•	a list of the states with OSHA-approved state plans

•	a list of OSHA regional offices

•	a list of all state agencies that can provide further information about OSHA standards (Consultation Project Directory)

•	OSHA's Internet site address

These agencies often have staff members who can help businesses develop programs for training employees. These agencies also can supply printed materials about the various OSHA standards.


Abbreviations

ACGIH	American Conference of Governmental Industrial Hygienists

ACS	American Chemical Society

ANSI	Standards Institute

API	American Petroleum Institute

BLS	Bureau of Labor Statistics

CAS	Chemical Abstracts Service (number issued by government)

CFR	Code of Federal Regulations

COSH	Council on Occupational Safety and Health

DOT	Department of Transportation

EPA	Environmental Protection Agency

HCP	Hazard Communication Program

HCS	Hazard Communication Standard

HMIDP	Hazardous Material Information Development Preparedness and Response Act

IARC	International Agency for Research on Cancer

IDLH	Immediately Dangerous to Life and Health

IUPAC	International Union of Pure and Applied Chemistry

LEL	Lower Explosive Limit

LFL	Lower Flammable Limit

MSDS	Material Safety Data Sheet

MSHA	Mine Safety and Health Administration

NAM	National Association of Manufacturers

NFPA	National Fire Protection Association

NIOSH	National Institute for Occupational Safety and Health

NOHS	National Occupational Hazard Survey

NPCA	National Paint and Coatings Association

NPRM	National Proposed Rule Making (Hazard Identification)

NTP	National Toxicology Program

OSHA	Occupational Safety and Health Administration

PEL	Permissible Exposure Limits

PPM	Parts Per Million

RCRA	Resource Conservation and Recovery Act

RTECS	Registry of Toxic Effects of Chemical Substances

SARA	Superfund Amendments and Reauthorization Act

SCBA	Self-Contained Breathing Apparatus

STEL	Short-Term Exposure Limits

TLV	Threshold Limit Value

TSCA	Toxic Substances Control Act

UEL	Upper Explosive Limit

UFL	Upper Flammable Limit


States with Approved Plans

States with OSHA-approved state plans are required to enforce safety and health standards that are "at least as effective" as the federal OSHA standards, although they may differ in some respects. Hazard communication standards may also differ somewhat according to the state in which the business is located. This section lists the states with OSHA-approved plans and the appropriate state offices to contact for more information.

Alaska

Department of Labor

Labor Standards and Safety Division

Occupational Safety and Health

Anchorage, Alaska

Phone: 907-269-4940

Internet: http://www.labor.state.ak.us/lss/oshhome.htm

Arizona

Industrial Commission

Occupational Safety and Health (ADOSH)

Phoenix, Arizona

Phone: 602-542-5795

Internet: http://www.ica.state.az.us/ADOSH/oshatop.htm

California

Department of Industrial Relations

Division of Occupational Safety and Health (DOSH)

San Francisco, California

Phone: 415-703-5100

Internet: http://www.dir.ca.gov/DOSH/dosh1.html

Connecticut

Department of Labor

Division of Occupational Safety and Health (CONN-OSHA)

Wethersfield, Connecticut

Phone: 860-566-4550

Internet: http://www.ctdol.state.ct.us/osha.osha.htm

(Connecticut's plan covers public sector employees only; private employees remain subject to federal OSHA.)

Hawaii

Department of Labor and Industrial Relations

Occupational Safety and Health Division (HIOSH)

Honolulu, Hawaii

Phone: 808-586-9116

Internet: http://www.state.hi.us/dlir/hiosh

Indiana

Department of Labor

Indiana OSHA Division (IOSHA)

Indianapolis, Indiana

Phone: 317-232-2693

Internet: http://www.state.in.gov/labor/iosha

Iowa

Iowa Workforce Development

Occupational Safety and Health (IOSHA)

Des Moines, Iowa

Phone: 515-242-5870

Internet: http://www.state.ia.us/government/wd/labor/iosh

Kentucky

Labor Cabinet

Occupational Safety and Health Program

Frankfort, Kentucky

Phone: 502-564-3070

Internet: http://www.state.kylabor.net/kyosh

Maryland

Division of Labor and Industry

Maryland Occupational Safety and Health (MOSH)

Baltimore, Maryland

Phone: 410-767-2215

Internet: http://www.dllr.state.md.us/labor

Michigan

Department of Consumer and Industry Services

Michigan OSHA (MIOSHA)

Lansing, Michigan

Phone:	517-322-1831 (general industry)

800-866-4674

Department of Consumer and Industry Services

Division of Occupational Health

Lansing, Michigan

Phone: 517-322-1608 (health)

Internet: http://www.cis.state.mi.us/bsr

Minnesota

Department of Labor and Industry

Occupational Safety and Health Division

St. Paul, Minnesota

Phone:	651-284-5050

877-470-6742

Internet: http://www.doli.state.mn.us/mnosha.html

Nevada

Department of Business and Industry

Division of Industrial Relations

Occupational Safety and Health Enforcement Section

Carson City, Nevada

Phone: 702-486-9044

Internet: http://dirweb.state.nv.us/oshes.htm

New Jersey

Department of Labor

Division of Public Safety and Occupational Safety and Health

Trenton, New Jersey

Phone: 609-292-3923

Internet: http://www.state.nj.us/labor/wps/psosh/peosh.htm

(New Jersey's plan covers public sector employees only; private employees remain subject to federal OSHA.)

New Mexico

Environment Department

Occupational Health and Safety Bureau

Santa Fe, New Mexico

Phone: 505-827-4230

Internet: http://www.nmenv.state.nm.us/ohsb/oshahome.htm

New York

Labor Department

Division of Safety and Health

Albany, New York

Phone: 518-457-3518

Internet: http://www.labor.state.ny.us

(New York's plan covers public sector employees only; private employees remain subject to federal OSHA.)

North Carolina

Department of Labor

Occupational Safety and Health Division

Raleigh, North Carolina

Phone:	919-807-2900

800-522-6762 (in-state)

Internet: http://www.dol.state.nc.us/osha/osh.htm

Oregon

Department of Consumer and Business Services

Oregon-OSHA

Salem, Oregon

Phone:	503-378-3272

800-922-2689 (in-state)

Internet: http://www.orosha.org

South Carolina

Department of Labor, Licensing, and Regulation

Labor Division-OSHA

Columbia, South Carolina

Phone: 803-896-4380

Internet: http://www.llr.state.sc.us

Tennessee

Department of Labor, Licensing and Regulation

Division of Occupational Safety and Health (TOSHA)

Nashville, Tennessee

Phone:	615-741-2793

800-325-9901

Internet: http://www.state.tn.us/labor-wfd/tosha.html

Utah

Industrial Commission

Occupational Safety and Health Division (UOSH)

Salt Lake City, Utah

Phone:	801-530-6901

800-530-5090

Internet: http://www.laborcommission.utah.gov

Vermont

Department of Labor and Industry

Vermont OSHA (VOSHA)

Montpelier, Vermont

Phone: 802-828-2765

Internet: http://www.state.vt.us/labind/vosha.htm

Virginia

Department of Labor and Industry

Occupational Safety and Health Compliance Division

Richmond, Virginia

Phone:	804-786-0574 (health)

804-786-2391 (safety)

Internet: http://www.dli.state.va.us

Washington

Department of Labor and Industries

Industrial Safety and Health Administration (WISHA)

Olympia, Washington

Phone:	360-902-5580

800-423-7233 (in-state)

Internet: http://www.lni.wa.gov/wisha

Wyoming

Department of Employment

Workers' Safety/OSHA

Cheyenne, Wyoming

Phone: 307-777-7786

Internet: http://wydoe.state.wy.us/osha


OSHA Regional and Area Offices

This section lists the OSHA Regional and Area Offices within the U.S. Department of Labor. These offices administer and enforce OSHA regulations, including hazard communication regulations. Contact these offices for additional information about OSHA.

Region I

Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont

U.S. Department of Labor

OSHA Regional Office

John F. Kennedy Federal Building, Room E340

Boston, Massachusetts 02203

Phone: 617-565-9860

Area Offices

Bridgeport, Connecticut

203-579-5581

Hartford, Connecticut

860-240-3152

Bangor, Maine

207-941-8177

Portland, Maine

207-780-3178

North Boston Office

Methuen, Massachusetts

617-565-8110

South Boston Office

Braintree, Massachusetts

617-565-6924

Springfield, Massachusetts

413-785-0123

Concord, New Hampshire

603-225-1629

Providence, Rhode Island

401-528-4669

Region II

New Jersey and New York

U.S. Department of Labor

OSHA Regional Office

201 Varick Street, Room 670

New York, New York 10014

Phone: 212-337-2378

Area Offices

Avenel, New Jersey

732-750-3270

Hasbrouck Heights, New Jersey

201-288-1700

Marlton, New Jersey

856-757-5181

Parsippany, New Jersey

973-263-1003

Albany, New York

518-464-4338

Bayside, New York

718-279-9060

Buffalo Office

Bowmansville, New York

716-684-3891

Long Island Office

Westbury, New York

516-334-3344

Manhattan Office

New York, New York

212-466-2482

Syracuse, New York

315-451-0808

Tarrytown, New York

914-524-7510

Region III

Delaware, District of Columbia, Maryland, Pennsylvania, Virginia, and West Virginia

U.S. Department of Labor

OSHA Regional Office

The Curtis Center - Suite 740 West

170 S. Independence Mall West

Philadelphia, Pennsylvania 19106-3309

Phone: 215-861-4900

Area Offices

Wilmington, Delaware

302-573-6518

Baltimore/Washington Office

Linthicum, Maryland

410-865-2055 (2056)

Allentown, Pennsylvania

610-776-0592

Erie, Pennsylvania

814-833-5758

Harrisburg, Pennsylvania

717-782-3902

Philadelphia, Pennsylvania

215-597-4955

Pittsburgh, Pennsylvania

412-395-4903

Wilkes-Barre, Pennsylvania

570-826-6538

Norfolk, Virginia

757-441-3820

Charleston, West Virginia

304-347-5937

Region IV

Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, and Tennessee

U.S. Department of Labor

OSHA Regional Office

61 Forsyth Street, SW

Atlanta, Georgia 30303

Phone: 404-562-2300

Area Offices

Birmingham, Alabama

205-731-1534

Mobile, Alabama

334-441-6131

Fort Lauderdale, Florida

954-424-0242

Jacksonville, Florida

904-232-2895

Tampa, Florida

813-626-1177

Atlanta East Office

Tucker, Georgia

770-493-6644

Atlanta West Office

Smyrna, Georgia

770-984-8700

Savannah, Georgia

912-652-4393

Frankfort, Kentucky

502-227-7024

Jackson, Mississippi

601-965-4606

Raleigh, North Carolina

919-856-4770

Columbia, South Carolina

803-765-5904

Nashville, Tennessee

615-781-5423

Region V

Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin

U.S. Department of Labor

OSHA Regional Office

230 South Dearborn Street, Room 3244

Chicago, Illinois 60604

Phone: 312-353-2220

Area Offices

Calumet City, Illinois

708-891-3800

Chicago Office

Des Plaines, Illinois

847-803-4800

Fairview Heights, Illinois

618-632-8612

North Aurora, Illinois

630-896-8700

Peoria, Illinois

309-671-7033

Indianapolis, Indiana

317-226-7290

Lansing, Michigan

517-327-0904

Minneapolis, Minnesota

612-664-5460

Cincinnati, Ohio

513-841-4132

Cleveland, Ohio

216-522-3818

Columbus, Ohio

614-469-5582

Toledo, Ohio

419-259-7542

Appleton, Wisconsin

920-734-4521

Eau Claire, Wisconsin

715-832-9019

Madison, Wisconsin

608-441-5388

Milwaukee, Wisconsin

414-297-3315

Region VI

Arkansas, Louisiana, New Mexico, Oklahoma, and Texas

U.S. Department of Labor

OSHA Regional Office

525 Griffin Street, Room 602

Dallas, Texas 75202

Phone: 214-767-4731

Area Offices

Little Rock, Arkansas

501-324-6291

Baton Rouge, Louisiana

225-389-0474

Albuquerque, New Mexico

505-248-5302

Oklahoma City, Oklahoma

405-278-9560

Austin, Texas

512-916-5783

Corpus Christi, Texas

361-888-3420

Dallas, Texas

214-320-2400 (2558)

El Paso, Texas

915-534-6521 (6252)

Fort Worth, Texas

817-428-2470

Houston North Office

Houston, Texas

281-591-2438

Houston South Office

Houston, Texas

281-286-0583 (0584)

Lubbock, Texas

806-472-7681 (7685)

Region VII

Iowa, Kansas, Missouri, and Nebraska

U.S. Department of Labor

OSHA Regional Office

City Center Square

1100 Main Street, Suite 800

Kansas City, Missouri 64105

Phone: 816-426-5861

Area Offices

Des Moines, Iowa

515-284-4794

Wichita, Kansas

316-269-6644

800-362-2896 (in-state)

Kansas City, Missouri

816-483-9531

800-892-2674 (in-state)

St. Louis, Missouri

314-425-4249

800-392-7743 (in-state)

Omaha, Nebraska

402-221-3182

800-642-8963 (in-state)

Region VIII

Colorado, Montana, North Dakota, South Dakota, Utah, and Wyoming

U.S. Department of Labor

OSHA Regional Office

1999 Broadway, Suite 1690

P.O. Box 46550

Denver, Colorado 80201-6550

Phone: 303-844-1600

Area Offices

Denver, Colorado

303-844-5285

800-755-7090

Englewood, Colorado

303-843-4500

800-669-5771

Billings, Montana

406-247-7494

800-488-7087

Bismarck, North Dakota

701-250-4521

800-473-7419

Salt Lake City, Utah

801-524-7900

Region IX

Arizona, California, Hawaii, and Nevada

U.S. Department of Labor

OSHA Regional Office

71 Stevenson Street, Suite 420

San Francisco, California 94105

Main Phone: 415-975-4310

For Technical Assistance: 800-475-4019

For Complaints - Accidents/Fatalities: 800-475-4020

For Publications Requests: 800-475-4022

Region X

Alaska, Idaho, Oregon, and Washington

U.S. Department of Labor

OSHA Regional Office

1111 Third Avenue, Suite 715

Seattle, Washington 98101-3212

Phone: 206-553-5930

Area Offices

Anchorage, Alaska

907-271-5152

Boise, Idaho

208-321-2960

Portland, Oregon

503-326-2251

Bellevue, Washington

206-553-7520

Other Relevant Addresses

OSHA Training Institute

Office of Training and Education

U.S. Department of Labor

1555 Times Drive

Des Plaines, Illinois 60018-1548

Phone:	847-297-4810

847-297-4876 (TDD)


OSHA/State Consultation Project Directory

Consultation programs provide free services to employers that request help in identifying and correcting specific hazards, want to improve their safety and health programs, or need further assistance in training and education. Funded by OSHA and delivered by well-trained professional staff of state governments, consultation services are comprehensive and include an appraisal of all workplace hazards, practices, and job safety and health programs; conferences and agreements with management; assistance in implementing recommendations; and a follow-up appraisal to ensure that any required corrections are made.

In a typical review of a company's operation, the consultant will examine the structural condition of the building, check equipment such as forklifts, examine storage conditions, check control of toxic substances and other environmental hazards, and confer with management about employee supervision and job training. The ultimate benefits of a successful consultation experience may include a highly effective safety and health program as well as recognition by OSHA.

For more information on consultation programs, contact the appropriate office in your state listed in this section.

Alabama

Safe State Program

University of Alabama

Tuscaloosa, Alabama

Phone:	205-348-3033

800-452-5928 (in-state)

Internet: http://bama.ua.edu/~deip/safest.html

Alaska

Department of Labor and Workforce Development

Division of Consultation and Training

Occupational Safety and Health

Anchorage, Alaska

Phone:	907-269-4955

800-656-4972 (in-state)

Internet: http://www.labor.state.ak.us/lss/oshhome.htm

Arizona

Industrial Commission

Division of Occupational Safety and Health (ADOSH)/Consultation Department

Phoenix, Arizona

Phone: 602-542-1695

Internet: http://www.ica.state.az.us/ADOSH/oshatop.htm

Arkansas

Department of Labor

OSHA Consultation Division

Little Rock, Arkansas

Phone:	501-682-4517 (Health)

501-682-4516 (Safety)

501-682-4521 (Consultation)

Internet: http://www.accessarkansas.org/labor/divisions/aosh_p1.html

California

Department of Industrial Relations

Cal/OSHA Consultation Service

San Francisco, California

Phone:	415-703-5270

800-963-9424

Internet: http://www.dir.ca.gov/DOSH/consultation.html

Colorado

Colorado State University

Colorado Consultation Program

Fort Collins, Colorado

Phone: 970-491-6151

Internet: http://www.bernardino.colostate.edu/enhealth/7c1.html

Connecticut

Department of Labor

Division of Occupational Safety and Health (CONN-OSHA)

Wethersfield, Connecticut

Phone: 860-566-4550

Internet: http://www.ctdol.state.ct.us/osha/consulti.htm

Delaware

Department of Labor

Division of Industrial Affairs

Occupational Safety and Health Administration (OSHA) Consultation Service

Wilmington, Delaware

Phone: 302-761-8200

Internet: http://www.delawareworks.com/divisions/industaffairs/occu.safety.htm

District of Columbia

Department of Employment Services

Labor Standards Bureau

Office of Occupational Safety and Health

Washington, DC

Phone: 202-671-1800

Internet: http://does.ci.washington.dc.us/services/wkr_osh.shtm

Florida

University of South Florida

Safety Florida Consultation Program

Department of Environmental and Occupational Health

College of Public Health

Tampa, Florida

Phone: 866-273-1105

Internet: http://www.safetyflorida.usf.edu

Georgia

Georgia Institute of Technology

7(c)(1) Onsite Consultation Program

Atlanta, Georgia

Phone: 404-894-2643

Internet: http://www.oshainfo.gatech.edu

Hawaii

Dept. of Labor and Industrial Relations

Consultation and Training Branch

Honolulu, Hawaii

Phone: 808-586-9100

Internet: http://www.state.hi.us/dlir/hiosh

Idaho

Boise State University

Occupational Safety and Health Program

Risk Management and Audit Services

Boise, Idaho

Phone: 208-426-3283

Internet: http://www2.boisestate.edu/ehs/consultation.htm

Illinois

Department of Commerce and Community Affairs

Industrial Services Division

Onsite Consultation Program

Chicago, Illinois

Phone:	312-814-2337

800-972-4216

Internet: http://www.commerce.state.il.us/workforce/OSHA/OSHA_home.htm

Indiana

Department of Labor

Bureau of Safety Education and Training

Indianapolis, Indiana

Phone: 317-232-2688

Internet: http://www.in.gov/labor/iosha

Iowa

Iowa Workforce Development

IOSH Consultation and Education

Des Moines, Iowa

Phone: 515-281-7629

Internet: http://www.state.ia.us/government/wd/labor/iosh

Kansas

Department of Human Resources

Division of Workers Compensation

Industrial Safety and Health Section

7(c)(1) Consultation Program

Topeka, Kansas

Phone: 785-296-7476

Internet: http://www.hr.state.ks.us/wc/html/wcish.htm

Kentucky

Labor Cabinet

Occupational Safety and Health Program

Division of Education and Training

Frankfort, Kentucky

Phone: 502-564-6895

Internet: http://www.kylabor.net/kyosh

Louisiana

Louisiana Works

Department of Labor

OSHA Consultation Program

Baton Rouge, Louisiana

Phone: 225-342-9601

Internet: http://www.ldol.state.la.us

Maine

Department of Labor

Bureau of Labor Standards

Workplace Safety and Health Division

Augusta, Maine

Phone:	207-624-6400

877-723-3345

Internet: http://www.state.me.us/labor/bls/worksafe.htm

SafetyWorks! Program: 877-723-3345

Maryland

Division of Labor and Industry

Maryland Occupational Safety and Health

MOSH Consultation Services

Baltimore, Maryland

Phone:	410-880-6131 or

301-483-8635

Internet: http://www.dllr.state.md.us/labor

Massachusetts

Department of Labor and Workforce Development

Division of Occupational Safety

Onsite Consultation Program

Boston, Massachusetts

Phone: 617-969-7177

Internet: http://www.state.ma.us/dos

Michigan

Department of Consumer and Industry Services

Bureau of Safety and Regulation (MIOSHA)

Consultation Education and Training Division (CET)

Lansing, Michigan

Phone: 517-322-1809

Internet: http://www.cis.state.mi.us/bsr

Minnesota

Department of Labor and Industry

MNOSHA Workplace Safety Consultation

St. Paul, Minnesota

Phone:	651-284-5060

800-657-3776

Internet: http://www.doli.state.mn.us/mnosha.html

Mississippi

Mississippi State University

Center for Safety and Health

Onsite Consultation Program

Jackson, Mississippi

Phone: 601-939-2047

Internet: http://msstate.edu/dept/csh

Missouri

Department of Labor and Industrial Relations

Division of Labor Standards

Onsite Safety and Health Consultation

Jefferson City, Missouri

Phone:	573-751-3403

800-475-2130 (option 4)

Internet: http://www.dolir.state.mo.us/ls/onsite/index.html

Montana

Department of Labor and Industry

Safety and Health Bureau

OSHA Consultation Project

Helena, Montana

Phone: 406-444-6418

Internet: http://erd.dli.state.mt.us/Safety/SboccSH.htm

Nebraska

Nebraska Workforce Development

Department of Labor

OSHA Consultation 21(d) Program

Lincoln, Nebraska

Phone: 402-471-4717

Internet: http//www.dol.state.ne.us/nwd

Nevada

Department of Business and Industry

Division of Industrial Relations

Safety Consultation and Training Section (SCATS)

Henderson, Nevada

Phone: 702-486-9159

Internet: http://4safenv.state.nv.us

New Hampshire

Department of Health and Human Services

Bureau of Health Risk Assessment

Occupational Safety and Health Consultation

Concord, New Hampshire

Phone:	603-271-4676 (health)

603-271-2024 (safety)

Internet: http://www.dhhs.state.nh.us

New Jersey

Department of Labor

Occupational Safety and Health Consultation Services

Trenton, New Jersey

Phone:	609-984-0785 (health)

609-292-0404 (safety)

Internet: http://www.state.nj.us/labor/wps/psosh/peosh.htm

New Mexico

Environment Department

Occupational Health and Safety Bureau

Consultation and Technical Services

Santa Fe, New Mexico

Phone: 505-827-4230

Internet: http://www.nmenv.state.nm.us/ohsb/consultation.htm

New York

Department of Labor

Division of Safety and Health

7(c)(1) Consultation Service

Albany, New York

Phone: 518-457-2238

Internet: http://www.labor.state.ny.us

North Carolina

Department of Labor

Occupational Safety and Health Division

Bureau of Consultative Services

Raleigh, North Carolina

Phone: 919-807-2899

Internet: http://www.dol.state.nc.us/osha/consult/consult.htm

North Dakota

Department of Health

Occupational Safety and Health Consultation Program

Division of Air Quality

Bismarck, North Dakota

Phone: 701-328-5188

Internet: http://www.ndsafety.net

Ohio

Department of Commerce

Division of Labor and Worker Safety

Occupational Safety and Health Administration

Onsite Consultation Services

Columbus, Ohio

Phone:	614-644-2631

800-282-1425

Internet: http://www.com.state.oh.us/odoc

Oklahoma

Department of Labor

OSHA Consultation Division

Oklahoma City, Oklahoma

Phone:	405-528-1500, ext. 275

888-269-5353 (outside Oklahoma City)

Internet: http://www.state.ok.us/~okdol/osha/

Oregon

Department of Consumer and Business Services

Oregon-OSHA Consultative Services

Salem, Oregon

Phone:	503-378-3272

800-922-2689 (in-state)

Internet: http://www.orosha.org

Pennsylvania

Indiana University of Pennsylvania

PA/OSHA Consultation Program

Indiana, Pennsylvania

Phone:	724-357-2396

800-382-1241 (in-state)

Internet: http://www.hhs.iup.edu/sa/OSHA/index.htm

Rhode Island

Department of Health

Occupational Health and Radiation Control

Providence, Rhode Island

Phone: 401-277-2438

Internet: http://www.state.ri.us/dohrad.htm

South Carolina

Department of Labor, Licensing, and Regulation

Office of OSHA Voluntary Programs

Consultation Division

Columbia, South Carolina

Phone: 803-734-9599

Internet: http://www.llr.state.sc.us

South Dakota

South Dakota State University

Engineering Extension

Onsite Technical Division

Brookings, South Dakota

Phone: 605-688-4101

Internet: http://www.engineering.sdstate.edu/~erc/EngExt/ext.htm

Tennessee

Department of Labor and Workforce Development

Division of Occupational Safety and Health (TOSHA)

TOSHA Consultative Services

Nashville, Tennessee

Phone: 615-741-7036

Internet: http://www.state.tn.us/labor-wfd/toshcons.html

Texas

Workers' Compensation Commission

Workers' Health and Safety Division

Austin, Texas

Phone: 512-804-4640

OSHCON Request Line: 800-687-7080

Internet: http://www.twcc.state.tx.us/services/oshcon.html

Utah

Labor Commission

Occupational Safety and Health Division (UOSH)

Consultation Services

Salt Lake City, Utah

Phone: 801-530-6855

Internet: http://laborcommission.utah.gov

Vermont

Department of Labor and Industry

Vermont OSHA (VOSHA)

Project Work Safe

Montpelier, Vermont

Phone:	802-828-2765

800-287-2765 (in-state)

Internet: http://www.state.vt.us/labind/vosha.htm

Virginia

Department of Labor and Industry

Occupational Safety and Health Consultation Division

Richmond, Virginia

Phone: 804-786-8707

Internet: http://www.dli.state.va.us

Washington

Department of Labor and Industries

Industrial Safety and Health Administration (WISHA)

Safety and Health Consultation

Olympia, Washington

Phone: 360-902-5735

Internet: http://www.lni.wa.gov/wisha

West Virginia

Commerce Bureau

Division of Labor

Safety and Health Consultation

Charleston, West Virginia

Phone: 304-558-7890

Internet: http://www.state.wv.us/labor

Wisconsin (Health)

Department of Health and Family Services

Division of Public Health

Bureau of Occupational Health

OSHA Consultation Program

Madison, Wisconsin

Phone: 608-266-0417

Internet: http://www.dhfs.state.wi.us/aboutdhfs/dph/dph.htm

Wisconsin (Safety)

Department of Commerce

Occupational Safety Consultation (WiSCon)

Waukesha, Wisconsin

Phone:	262-523-3040

800-947-0553

Internet: http://www.commerce.state.wi.us/MT/MT-FAX-0928.html

Wyoming

Department of Employment

Workers' Safety/OSHA

Cheyenne, Wyoming

Phone: 307-777-7786

Internet: http://wydoe.state.wy.us/osha

Other Relevant Addresses

OSHA Training Institute

OSHA Office of Education and Training

Consultation Training Coordination

Des Plaines, Illinois

Phone: 847-297-4810

Laboratory Services

Wisconsin Occupational Health Laboratory

Madison, Wisconsin

Phone: 608-224-6210


OSHA Internet Site

OSHA's Internet site contains a great deal of useful information. The site is located at http://www.osha.gov and contains information on OSHA's:

•	offices and regions

•	programs and initiatives

•	statistics and inspection data

•	Voluntary Protection Program (VPP), including eligibility requirements

•	publications

•	posters

•	new "Workers' Page"

•	news releases

•	directives and interpretations

•	standards and regulations


Titles Available from Summers Press

National and Regional Employer's Guides®

Medical Employer's Guide

Pacific Northwest Employer's Guide: Oregon and Washington

Southern Employer's Guide: Alabama and Mississippi

U.S. Employer's Guide

State Employer's Guides®

California Employer's Guide

Florida Employer's Guide

Georgia Employer's Guide

Illinois Employer's Guide

Indiana Employer's Guide

Maryland Employer's Guide

Michigan Employer's Guide

New York Employer's Guide

North Carolina Employer's Guide

Ohio Employer's Guide

Pennsylvania Employer's Guide

Tennessee Employer's Guide

Virginia Employer's Guide

Wisconsin Employer's Guide

OSHA and EPA: Compliance and Training Guides

Automotive Workplace Guide to EPA and OSHA

California OSHA Compliance Guide

California OSHA Guide for the Construction Industry

California OSHA Training Guide

California OSHA Training Guide, Spanish Handouts and Tests

EPA Compliance Guide for Hazardous Waste

OSHA Compliance Guide (available as a book or on CD)

OSHA Guide for the Construction Industry

OSHA Training Guide (available as a book or on CD)

Law and Strategy Guides

Employer's Guide to Managing Personnel Costs

Employer's Guide to Workplace Privacy

Workers' Compensation Law and Strategy Guide

Software

OSHA Compliance Guide (available on CD)

OSHA Recordkeeping Software (available on CD)

OSHA Training Guide (available on CD)

Sample Safety Plans (available on CD)

800-743-6491

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