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My friends at OSHA tell me that the most commonly applicable (and cited) standards are as follows: Ø OSHA Log Record Keeping – All companies with ten or more employees are required to maintain employee injury and illness logs. Primary form—OSHA 300 Log. Ø Personal Protective Equipment – All companies whose employees need personal protective equipment to safely perform their jobs (e.g. hard hats, work shoes, gloves, aprons and goggles) must evaluate the equipment. Ø Hazardous Chemicals – If in the course of their employment, employees use any of the chemicals contained in OSHA’s hazardous chemical list (24CFR1910.1200) employers are required to develop a written hazard communication program and maintain material safety data information. Meet certain labeling requirements. Provide employees with hazardous communication training. Ø Lock-out/Tag-out – If employees perform service or maintenance on equipment that has stored energy capable of being released while work is being performed (e.g. conveyor belts, cranes, dock levelers) the employer is required to have in place written measures to lock or tag out all such machines and to provide necessary training to all employees. Ø Powered Industrial Truck Maintenance and Training – As of March 1999, all employers who have employees using powered industrial trucks (forklifts, pallet jacks, etc.) are required to provide such employees with formal training in 22 areas before they are allowed to operate the equipment. In addition, employers are required to meet certain daily and periodic truck maintenance obligation. All training and maintenance procedures must be documented and the trainer must be qualified. A directive letter dated 11/2000 added “A qualified trainer would be a person who by possession of a Recognized Degree, Certificate or Professional Standing has the knowledge, training and experience to train and evaluate”. Ø Occupational Noise Exposure: If there are areas in the workplace where people have trouble hearing each other because of the noise level of the equipment, it would be reasonable to assume that the employer is obligated to test those work areas (an 8 hour, time-weighted average of 85 decibels). If the noise levels are too high the standard requires the development and implementation of a Full hearing conservation program, including work area noise level tests, provision of hearing protection and enforcement of the use of hearing protection along with training in the use of such equipment. Ø Blood born Pathogens: Do not think that the standard only applies to Health Care Facilities. OSHA also enforces it with companies where First Aid is administered by “designated employees”. Ø Permit Required Confined Spaces: This standard applies where the worksite contains spaces with restrictive means of entry or exit that are large enough to allow an employee to enter but are not designed for continuous occupancy. The standard further goes on to describe Air Testing, Emergency Response Training, and a Written Plan. A dock leveler pit would be a confined space but it is not a “Permit Required” space as most docks are in well ventilated areas. Ø Respiratory Protection: If employers require protective respiratory equipment to prevent exposure to health hazards, or if a company reasonably anticipates the need to use such equipment (once every six months would be reasonable). OSHA requires the development and implementation of a written program. The provision of needed equipment, enforcement of equipment use, cleaning and maintenance and the provision of annual training, medical exams and respirator fit testing. Ø Ergonomics: Do not think that the ergonomic issue is dead. The so called “New Standards” was killed but the old rules still apply. If an employer has a large number of work related muscle skeletal injuries (strains, sprains to backs, knees and wrists) as compared to other employers in the same industry, that employer is more likely to be cited during an OSHA inspection. Ø OSHA Poster: All employers (no matter the size) are required to hang an OSHA posters on their employee bulletin board. The poster can be obtained from the local OSHA office. Are your workers properly trained to adjust to change? |
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