Q: Does OSHA permit the use of stilts when doing drywall and taping? A: Stilts are permitted, but make sure the working area is clean and free of tripping hazards. Also, if you are working in an area that has guardrails you will need to add extra protection to ensure the employees on stilts cannot fall over the top of the guardrail.

Q: Do employees who voluntarily wear dust masks still need to sign Appendix D?

A: If you have any employee who voluntarily wears a dust mask, then they must review and sign Appendix D.

Get your safety questions answered today by contacting us at (724) 776-1003.

Q: We have come upon a concern in our industry. The concern is a shock hazard if we are using a shovel to locate a water service with a potential “bad” electric line nearby. Can you aid me in finding if OSHA has a regulation on the following questions?

• Does OSHA consider or recognize a wood shovel handle as non-conductive?
• Is a fiberglass non-conductive handle required by OSHA in this instance?

A: Per OSHA, a wood shovel would be considered conductive, and they do not recommend using a fiberglass non-conductive handle. As far as the “bad” electric lines, please see 1926.651(b)(4). Also, you would want to conduct a one call to identify the lines and also ensure that all lines are de-energized to avoid any potential shock hazard.

Q: Which electrical panels are required to be labeled as arch flash warning and what should we look for?

A: OSHA requires employers to mark electrical equipment with descriptive markings, including the equipment’s voltage, current, wattage, or other ratings as necessary…

Q: Which electrical panels are required to be labeled as an arc flash warning and what should we look for?

A: OSHA requires employers to mark electrical equipment with descriptive markings, including the equipment’s voltage, current, wattage, or…

Q: What are the electrical control standards according to OSHA?

A: 1926.417(a) Controls. Controls that are to be deactivated during the course of work on energized or deenergized equipment or circuits shall be tagged.1926.417(b) Equipment and circuits. Equipment or circuits that are deenergized shall be rendered inoperative and shall have tags attached at all points where such equipment or circuits can be energized.1926.417(c) Tags.

Q: What are the requirements specifically for opening up an electrical panel if we were to outfit our men?

A: According to the NFPA 70E (Electrical Safety in the Workplace), there are a few requirements pertaining to this process. First, make sure all unqualified persons maintain a distance from the exposed energized conductors or circuit parts and no one should cross the arc flash boundary unless they are wearing the appropriate personal protective clothing. Since that the employees will be remove…

Q: My employees are working with a 480 volts panel what PPE do they need?

A: The PPE requirement for working with electrical equipment various for each situation. The National Fire Protection Agency (NFPA) classifies electrical work in categories from 0 to 4. The higher the category number the more personal protective equipment is required. You stated employees are working with 480 volts, that is part of the information needed. The other information needed is what parts of the electrical box they are working on. With the box being rated at 480 volts, this falls under categories 0-2. A 0 rating would require the employees to be wearing non-insulated clothes, safety glasses, etc. while a 2 rating would require them to be wearing fire resistant clothing with an ARC flash rating of a 8. Fire resistant clothing is special clothing outside of the normal work wear, some shirts will list their ARC rating on the tags. The employees should always be working with non-conductive tools, preferably rubber or hard plastic along with wearing safety glasses or a face shield when working with electrical hazards.

Is maintaining the highest level of safety easy?  Will you be able to think of all the hazards your workers may face?  Probably not, as no one can think of everything.

Thankfully, we can benefit from the safety community’s collective body of knowledge with the help of OSHA’s annual list of the Top 10 Most Frequently Cited Standards.

Review the list and ask yourself, did you violate any of these?

Q: If the prong is damaged on an extension cord, is it permissible to replace the prong with an approved one, provided the repair is done by a qualified electrician?

A: Yes, OSHA states “Extension cords used in construction may be repaired, so long as the repair returns the cord to the “approved” state required by 1926.403(a)”

Q: How close can you get equipment for drilling to a live power line?

A: Under OSHA 1910.333 standard for voltages to ground 50kV or below you can get within 10 feet.  For voltages to ground over 50kV you would need to be 10 feet away plus 4 inches for every 10kV over 50kV.

Q: Is it acceptable to cut the end off of a damaged cord and replace it with a new plug?

A: OSHA will allow this type of repair as long as the plug is replaced with an “approved” plug (i.e., by a testing laboratory such as factory mutual, underwriters laboratories, etc.).

Q: Are E-Stops required for all machines?

A: According to OSHA, E-Stops are not required on all machinery. They encourage the use of E-Stops, but do not allow them to be used instead of machine guarding or lockout/tagout purposes. This OSHA article that has good information on machine guarding and emergency stops.

Q: Are you required to test e-stops, if so what frequency?

A: There is no direct regulation, however it is a good company practice. It would be recommended for testing to be conducted weekly, monthly, or at most quarterly.

Q: I have a trench that is currently 6 feet high on both sides.  I want to adjust it so that a protective system does not have to be used.  If I adjust it to be four feet, will I need a protective system?

A: For trenching, a protective system is required for a trench 5 feet deep or greater.  Therefore, if you would adjust your trench to make the edges only four feet high, a competent person may determine that a protective system is not required.

Q: Is 1 to 1 sloping while we are excavating a basement alright?

A: Most soil is type C so they would need 1.5 to 1 since they are digging at 12 feet deep trench.

Q: Are you permitted to dig 1-2 feet below the shoring box in a 4×5 trench?
A: Yes, according to 1926.652(e)(2)(i), you can excavate no more than 2 feet below the bottom of the support system, only if the support system itself can handle and resist the forces calculated for the full depth of the trench and if there are no signs of a loss of soil from below or behind the support system…

Q: The rollover protection on an excavator was damaged by a tree.  Does this need to be repaired by a professional or can we do it in-house?

A:  You must remove unsafe materials and equipment from service until a registered professional engineer evaluates and approves them for use.  OSHA Publication on Excavations

Q: What are the OSHA requirements for eyewash stations?

A: OSHA requires the following:  1910.151(c). Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use…

Q: What are our options for employees who wear prescription eye glasses in the workplace?

A: 1910.132(h)(2):The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eye wear, provided that the employer permits such items to be worn off the job-site.

Please remember that regular eye glasses are not considered eye protection. All prescription safety glasses should have the ANSI Z87 rating to be adequate for the work area.

Q. Is there a height that the eyewash station needs to be?

A. There is no OSHA standard that gives a height but it does need to be readily accessible. They would be able to cite through the general duty clause based off ANSI Z358.1. The ANSI standard states the Eyewash station should be between 33 inches and 53 inches.

Q: Is there an OSHA rule about eye wash stations and whether it MUST be a cold water station or whether the water can be tempered.

A: OSHA has a rule about eye wash stations that states the need for eye washes in areas where hazards are present but it does not state specific requirement as to the water temperature. OSHA relies on the ANSI Standard Z358.1 for specifics requirements pertaining to eye washes. ANSI specifies that the water must be tempered between 60 and 100 degrees F. In the event of an OSHA inspection, they would refer to the ANSI standard if necessary. I’ve attached a link that has more information about eyewashes stations for your reference.

Q: What is the requirement for hand-on fire extinguisher training regarding the number of employees that must be trained? Can we train our own employees?

A: Per OSHA’s Portable fire extinguishers standard, 1910.157, you must train employees who are designated to operate a fire extinguisher upon initial assignment and at least annually thereafter. If you do not have any employees designated to use a fire extinguisher, meaning they are required to evacuate and not fight a fire, then the hands-on training is not required. You can perform the training yourselves as long as the employees are actually putting out a fire with the fire extinguishers. We recommend contacting your local fire department for the training though. Also, OSHA has no requirement on the number of employees that need to be designated to use the fire extinguishers.

Q: How often do fire alarms, sprinkler systems, and fire extinguishers need inspected?

A: Fire alarms must be inspected every two months if unsupervised, and one a year for supervised systems. A supervised alarm means…

Q. We have an audible alarm system in the plant with pull stations at all exits.  Are we required to have an audible alarm in every building / room?  We are specifically wondering about storage rooms or closets.

A. OSHA requires that any employee alarm if capable of being perceived above and noise or light levels by all employees in the affected portions of the workplace…

Q: Where do fire extinguishers need to be located throughout the facility?

A: Fire extinguishers need to be place 75 feet from class A fire and 50 feet from class B fire which is flammable chemicals.

Q: Are fire extinguishers required for employee company cars?

A: Although recommended to be available along with proper training, fire extinguishers are not required for company cars unless the vehicle falls under 1926.601 construction requirements.

Q: Where should we hang our evacuation maps?

A: By all the main exits…

Q: How often do fire alarms, sprinkler systems, and fire extinguishers need inspected?

A: Fire alarms must be inspected every two months if unsupervised, and one a year for supervised systems. A supervised alarm means…

Q. We have an audible alarm system in the plant with pull stations at all exits.  Are we required to have an audible alarm in every building / room?  We are specifically wondering about storage rooms or closets.

A. OSHA requires that any employee alarm if capable of being perceived above and noise or light levels by all employees in the affected portions of the workplace…

Q: What are the minimum requirements for fire extinguishers on large construction equipment?

A: The fire protection and prevention standard (29 CFR 1926.150) does not state any specific weight or size requirements for fire extinguishers on construction equipment.  However…

Q: What is the requirement for hand-on fire extinguisher training regarding the number of employees that must be trained? Can we train our own employees?

A: Per OSHA’s Portable fire extinguishers standard, 1910.157, you must train employees who are designated to operate a fire extinguisher upon initial assignment and at least annually thereafter. If you do not have any employees designated to use a fire extinguisher, meaning they are required to evacuate and not fight a fire, then the hands-on training is not required. You can perform the training yourselves as long as the employees are actually putting out a fire with the fire extinguishers. We recommend contacting your local fire department for the training though. Also, OSHA has no requirement on the number of employees that need to be designated to use the fire extinguishers.

Q: Are fire extinguishers required for my facility that contains a sprinkler system?

A: 1910.157(d)(3) The employer may use uniformly spaced standpipe systems or hose stations connected to a sprinkler system installed for emergency use by employees instead of…

Q. Can you provide any specifics on the required fire extinguishers for our company trucks?

A. OSHA does not have any requirements for fire extinguishers…

Q: How often do fire alarms, sprinkler systems, and fire extinguishers need inspected?

A: Fire alarms must be inspected every two months if unsupervised, and one a year for supervised systems. A supervised alarm means…

Q: Where do fire extinguishers need to be located throughout the facility?

A: Fire extinguishers need to be place 75 feet from class A fire and 50 feet from class B fire which is flammable chemicals.

Q: Are fire extinguishers required for employee company cars?

A: Although recommended to be available along with proper training, fire extinguishers are not required for company cars unless the vehicle falls under 1926.601 construction requirements.

Q: Are fire extinguishers required for employee company cars?

A: Although recommended to be available along with proper training, fire extinguishers are not required for company cars unless the vehicle falls under 1926.601 construction requirements.

Q: Are fire extinguishers required for employee company cars?

A: Although recommended to be available along with proper training, fire extinguishers are not required for company cars unless the vehicle falls under 1926.601 construction requirements.

Q: Are fire extinguishers required for employee company cars?

A: Although recommended to be available along with proper training, fire extinguishers are not required for company cars unless the vehicle falls under 1926.601 construction requirements.

Q: How high off of the floor does a fire extinguisher need to be mounted?

A: Fire extinguishers need to be mounted and identified so that they are readily accessible to employees without subjecting them to possible injury. Generally, the carrying handle should be placed 3-5 feet above the floor.

Q: Is obtaining medical clearance for employees who wear respirators a voluntary program? and does it need to only be done once?

A: Medical clearance for employees who wear respirators is mandatory. Additionally…

Q: Do we need chip guards on the air gun nozzle?

A: Yes, a chip guard must be used when compressed air is used for…

Q: Do I need to have a horn for my overhead crane and should my employees wear hard hats? Do I need a checklist for performing work in the forklift man basket?

A: Yes your employees should wear hard hats as the crane creates an overhead hazard, which could result in falling objects. The crane does not need a horn and OSHA does not require the documentation of an inspection of the man basket but I recommend that you use one in case of an OSHA inspection.

Q: Is there a regulation or standard that states a company may not apply stickers to a hard hat?

A: No there is no regulation or standard stating that but one thing that you want to ensure is that the sticker being applied will not affect the shell of the hardhat. Some stickers contain adhesives that may break down the outer shell and reduce the original protection rating. It is recommended to keep the stickers to a minimum so you can always see the shell and ensure that it is still in good condition.

Q: If we are labeling containers internally, how must they be labeled? Do they need to have the six section GHS labeling?

A: Under HazCom 2012, workplace labels are still performance based — meaning OSHA doesn’t tell employers exactly what has to go on secondary container labels, but rather labels compliance by how well it does its job: effectively communicating hazards. OSHA says explicitly in the final rule on HazCom 2012, and elsewhere, that employers can continue to use their…

Q: How do you protect your employees who perform hot work on stainless steel?

A: When your employees are welding on stainless steel, you are exposing your employees to a hexavalent chromium exposure…

Is maintaining the highest level of safety easy?  Will you be able to think of all the hazards your workers may face?  Probably not, as no one can think of everything.

Thankfully, we can benefit from the safety community’s collective body of knowledge with the help of OSHA’s annual list of the Top 10 Most Frequently Cited Standards.

Review the list and ask yourself, did you violate any of these?

Q: Is it required to maintain old safety data sheets after you receive an updated version?

A: Yes. All SDS’s must be retained for 30 years. An employer may keep record of the chemical used, where it was used and when…

Q:  Can you tell me where it states that the Supervisor Training is required to be refreshed annually like the HAZWOPER 8 hour?

A:  OSHA’s requirement for the refresher training is as follows:1910.120(e)(8) Refresher training. Employees specified in paragraph (e)(1) of this section, and managers and supervisors specified in paragraph (e)(4) of this section, shall receive eight hours of refresher training annually on the items specified in paragraph (e)(2) and/or (e)(4) of this se…

Q: We are going onto a landfill to do some sampling.  No hazardous waste has, is, or ever will be disposed of in the landfill.  Is Hazwoper training required?  If not, what training is required?

A: As long as there is no hazardous waste OSHA’s Hazwoper Regulation doesn’t apply.  OSHA’s Hazard Communication Standard applies instead.

Q: Our Cardiologist would like to partition her suite so that she and her nurse may eat back there. This suite is a place of treatment but none of their patient pose a zoonotic threat. So we were going to purchase panel curtains from IKEA and hang them where the suite “L’s” that way she can move her desk back there and they are able to eat per OSHA regulations, would this be alright?

A: The other question pertaining to the treatment suite also does not have a specific OSHA regulation which addre…

Q: Does a deaf employee still have to wear hearing protection?

A: In regard to hearing protection, even employees who have been diagnosed with severe or profound deafness may have some residual hearing that needs to be protected from additional loss. Therefore…

Q: Does a deaf employee still have to wear hearing protection?

A: In regard to hearing protection, even employees who have been diagnosed with severe or profound deafness may have some residual hearing that needs to be protected from additional loss. Therefore, OSHA has taken the position that the requirements for using hearing protection in accordance with 29 CFR 1910.95(b)(1) and 1910.95(i)(2) apply to deaf employees.

Q: Is a full-blown hearing conservation program needed if employees are exposed to high noise levels a few times a year?

A: Yes, according to an OSHA Interpretation, “One day (of exposure). The occupational noise exposure standard requires that all employees exposed to noise levels at or above 85 dB on an 8-hour (TWA) must be included in a HCP.

Can you hear me now? A guide to hearing protection in the industrial workplace. By Jack Rubinger – It stands to reason that a 4 mile long, ½ mile deep pit mine would require immensely powerful and gigantic trucks to haul iron ore from bottom to top. Along with the sheer enormity is the overpowering noise these trucks create. And that’s a bad situation because noisy trucks are not in compliance with the Mine Safety and Health Administration (MSHA).Larry Hansen, Aeroacoustic Engineering Consulting…

Q:  We bring in an audiometric testing mobile to administer the tests once a year.  Sometimes they don’t get a good reading or there’s a red flag.  The employees who have this happen need to go to their main office to be retested.  Does the employer need to pay the employee for the time spent going to take the re-test?

A:  The audiometric testing is required to be provided at no cost to the employee.  Whether or not the employee is to be paid for the time spen…

Q:  We have all of our employees undergo audiometric testing each year including me (president/owner of company).  Do I still need to go through the testing if I no longer work on the floor?

A:  Audiometric testing is no longer needed if the occupational exposure has decreased below the action level of 85 dBA.

Q.  What is a hearing shift and does this apply to workers?

A. The hearing shift, or standard threshold shift, is in reference to an employee’s loss of hearing. Once it’s determined that an employee or employees are exposed to noise levels above OSHA’s action level of 85 dBA the employer needs to take certain actions.

Q: How many days per year would an employee have to be exposed to an environment with noise levels in excess of 85 decibels on an  8-Hour (TWA) before the employee is required to be in the hearing conservation program?

A: OSHA requires any employee who is exposed to noise levels above 85 dB…

Q: How many days per year would an employee have to be exposed to an environment with noise levels in excess of 85 decibels on an  8-Hour (TWA) before the employee is required to be in the hearing conservation program?

A: OSHA requires any employee who is exposed to noise levels above 85 dB…

Q: Does a deaf employee still have to wear hearing protection?

A: In regard to hearing protection, even employees who have been diagnosed with severe or profound deafness may have some residual hearing that needs to be protected from additional loss. Therefore…

Q: Does a deaf employee still have to wear hearing protection?

A: Even  employees who have been diagnosed with severe or profound deafness may have some residual hearing that needs to be protected from additional loss. Therefore, OSHA has taken the position that the requirements for using hearing protection in accordance with 29 CFR 1910.95(b)(1) and 1910.95(i)(2) apply to deaf employees.

It’s that time of year to open up the swimming pool, bring out the grill, dust off the golf clubs and enjoy the outdoors! It’s also that time of year where heat related hazards are present. Every year, thousands of workers experience adverse health effects from occupational heat exposure. Workers who are exposed to high air temperatures, radiant heat sources, high humidity, direct physical contact with hot objects and strenuous activities should be aware of potential heat-related illness.

The National Driller set out to write this article to help drill sites keep everyone safe on the job this summer. Jeff Lancaster, SGE, President of Lancaster Safety Consulting, Inc. was interviewed among others to help pinpoint what steps can be taken to plan for accident prevention.

Q: How often do I need to inspect our hoist and what are the inspecting rules?

A: OSHA requires that all hoisting equipment be regularly inspected according to standards set by the individual manufacturer and…

Q: Our maintenance department is interested in purchasing a crane man basket to perform work on elevated issues, particularly related to our 25′ high wheelabrator. They have requested that the lift also be suited to act as a forklift attachable work platform. When elevated work on the machine must be performed, a ladder is used in an unsafe manner because our current man lift basket is too large to access the tight space.

Q: How often do I need to inspect our hoist and what are the inspecting rules?

A: OSHA requires that all hoisting equipment be regularly inspected according to standards set by the individual manufacturer and…

Q: How do you protect your employees who perform hot work on stainless steel?

A: When your employees are welding on stainless steel, you are exposing your employees to a hexavalent chromium exposure…

Q: What are the safety requirements for hanging wood fascia while working off of a ladder? Do the employees need to be tied off?

A: You are required to maintain three points of contact at all times and are not permitted to work off of the top step of the ladder. as long as you meet those requirements, you would not have to be tied off.

I reached out to Chris and provided information and feedback regarding his questions:
Subject: Working over Water and Ladder Safety
Q1: What are the requirements for fall protection over the water?
a. Is a USCG approved life vest acceptable at all height levels? At what height would fall protection be required, if at all?
Answer: 
• When working above water, employers must provide fall protection if the distance from the walking/working surfaces to the water’s is 6 feet (1.8 m) or more. Each employee on a walking/working surface (horizontal or vertical) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrails systems, safety net systems, or personal fall arrest systems.
• The use of USCG approved life vests are what is required by OSHA regulations. So that is great that you already have that prepared. However, if you use a continuous fall protection system (without exception) to prevent employees from falling into the water, the use of USCG approved life vests is not required.
• However, the use of ring buoys and skiff are required. This device addresses the hazards that may occur in the event of a failure of operation of fall protection devices, or the lapse of their use.

Q2: What are the requirements for ladders in regards to fall protection?
a. I cannot locate any information on height requirements, types of ladders, cages, etc.
Answer: 
• There is no requirement that states which type of ladder is to be used (fixed or portable), however it is recommended that if the primary use of that specific ladder is for the transportation of employees into and out of work areas, a fixed ladder is used.
For Fixed Ladders:
o Fixed ladders shall be provided with cages, wells, ladder safety devices, or self-retracting lifelines where the length of the climb is less than 24 feet (7.3 m) above lower levels.
o Where the length of a climb exceeds 24 feet (7.3 m), fixed ladders shall be equipped with one of the following:
– Ladder safety device;
– Self-retracting lifelines, and rest platforms at intervals not to exceed 150 feet (45.7 m); or
– A cage or well, and multiple ladder sections, with each ladder section not exceeding 50 feet (15.2 m) in length. Ladder sections shall be offset from adjacent sections, and landing platforms shall be provided at maximum intervals of 50 feet (15.2m).
Portable Ladders:
– Neither the ladder standard (29 CFR 1926, subpart x) nor the fall protection standard (29 CFR 1926, subpart M) requires fall protection for workers while working on portable ladders.
– However, if you are working for a General Contractor, they may require that subcontractors implement a personal fall arrest system when working on ladders 6 feet or higher.
I reached out to Chris and provided information and feedback regarding his questions:
Subject: Working over Water and Ladder Safety
Q1: What are the requirements for fall protection over the water?
a. Is a USCG approved life vest acceptable at all height levels? At what height would fall protection be required, if at all?
Answer: 
• When working above water, employers must provide fall protection if the distance from the walking/working surfaces to the water’s is 6 feet (1.8 m) or more. Each employee on a walking/working surface (horizontal or vertical) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrails systems, safety net systems, or personal fall arrest systems.
• The use of USCG approved life vests are what is required by OSHA regulations. So that is great that you already have that prepared. However, if you use a continuous fall protection system (without exception) to prevent employees from falling into the water, the use of USCG approved life vests is not required.
• However, the use of ring buoys and skiff are required. This device addresses the hazards that may occur in the event of a failure of operation of fall protection devices, or the lapse of their use.

Q2: What are the requirements for ladders in regards to fall protection?
a. I cannot locate any information on height requirements, types of ladders, cages, etc.
Answer: 
• There is no requirement that states which type of ladder is to be used (fixed or portable), however it is recommended that if the primary use of that specific ladder is for the transportation of employees into and out of work areas, a fixed ladder is used.
For Fixed Ladders:
o Fixed ladders shall be provided with cages, wells, ladder safety devices, or self-retracting lifelines where the length of the climb is less than 24 feet (7.3 m) above lower levels.
o Where the length of a climb exceeds 24 feet (7.3 m), fixed ladders shall be equipped with one of the following:
– Ladder safety device;
– Self-retracting lifelines, and rest platforms at intervals not to exceed 150 feet (45.7 m); or
– A cage or well, and multiple ladder sections, with each ladder section not exceeding 50 feet (15.2 m) in length. Ladder sections shall be offset from adjacent sections, and landing platforms shall be provided at maximum intervals of 50 feet (15.2m).
Portable Ladders:
– Neither the ladder standard (29 CFR 1926, subpart x) nor the fall protection standard (29 CFR 1926, subpart M) requires fall protection for workers while working on portable ladders.
– However, if you are working for a General Contractor, they may require that subcontractors implement a personal fall arrest system when working on ladders 6 feet or higher.

Q: What are the requirements for ladders in regards to fall protection?
a. I cannot locate any information on height requirements, types of ladders, cages, etc.

A: There is no requirement that states which type of ladder is to be used (fixed or portable), however it is recommended…

Q: We have a machine that is about 8-10 feet in the air and the employees work on top of it. Do they need to be tied off?

A: If an employee is exposed to a drop greater than 4 feet, fall protection must be provided. In this instance, there could be a restraint attached to the machine that they could tie off to. Guard rails could also be used if feasible as well as a rolling ladder or scaffolding.

Q: Do employees have to use the ladder to access scaffolding on the jobsite.

A: Yes the employees should use the ladders to access scaffolding. OSHA standard on ladder access to scaffolding is :

1926.451(e)(1)

When scaffold platforms are more than 2 feet (0.6 m) above or below a point of access, portable ladders, hook-on ladders, attachable ladders, stair towers (scaffold stairways/towers), stairway-type ladders (such as ladder stands), ramps, walkways, integral prefabricated scaffold access, or direct access from another scaffold, structure, personnel hoist, or similar surface shall be used. Cross braces shall not be used as a means of access.

Is maintaining the highest level of safety easy?  Will you be able to think of all the hazards your workers may face?  Probably not, as no one can think of everything.

Thankfully, we can benefit from the safety community’s collective body of knowledge with the help of OSHA’s annual list of the Top 10 Most Frequently Cited Standards.

Review the list and ask yourself, did you violate any of these?

Q: What is the safety requirements for a 32’ climb to get to a LAMAR sign? They are using a ladder. A: If the sign has a fixed ladder the manufacturer should have installed the ladder to meet the following requirement: 1926.1053(a)(18) Fixed ladders shall be provided with cages, wells, ladder safety devices, or self-retracting lifelines where the length of climb is less than 24 feet (7.3 m) but the top of the ladder is at a distance greater than 24 feet (7.3 m) above lower levels.

Q: When using a ladder what do you do when you cannot have the ladder properly tied off?

A: In this case the employees are working on a residential roof with a 6-12 pitch. It was instructed to insert a screw into the edge of the roof at a good position so they are able to tie the ladder off securely. When they are working on the finishing touches they are to leave the section that the ladder is tied off to for last.

Q:  Does a mobile ladder platform need to have fall protection?

A:  Yes, OSHA considers these types of ladders working surfaces and they need to have fall protection if they are 4’ or taller.

Q: When employees are climbing ladders to do job tasks such as changing a light bulb do they need to be tied off?

A: No, fall protection is not required for employees climbing or working on portable ladders.

Q: Does it matter if you use a fiberglass ladder or an aluminum ladder when doing framing on a house when there is no electrical work being done?

A: No, it does not matter as long as each ladder has the proper warning labels on them.

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

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

Q: Do you need to use a fall protection system when climbing a step ladder that is greater than six feet high?

A: No, you do not need to use fall protection when climbing the step ladder.  You only need to use fall protection if you are climbing a fixed ladder.

Q: We have a “V-type” free standing step ladder, can we fold it and lean it against a wall? Some extension ladders are too tall.

A: No, because that is not how the ladder is designed, that will affect the stability of the step ladder.
For more information on buying the proper ladder…

Q: Some of the decals on the ladders are worn off or illegible. Do we have to go back to the manufacturer of the ladder to get replacement decals or can we get them from somewhere else?

A: Any applicable information specific to the ladder type, warnings or ratings shall be legible to the user.  The type of label would be specific to each manufacturer since products may differ.  Manufacturers may offer replacement labels.  However, due to liability concerns, it is do…

Q: Is there a minimum class that the ladders have to be rated? Can the ladders be wooden, aluminum and/or steel?

A: This all depends on the type of ladder, where the ladder will be used, and the type of forces exerted on the ladder.  Typically ladders have several different ratings. Consider factors such as proximity of electrical lines or systems, contaminants such as chemicals and how they will have an effect on the ladder material, weight of the average individual who will be using t…

Q:  Do you have to have fall protection on while working from a portable ladder?

A:  No:  See OSHA’s Standard Interpretation

Q: I have a ladder 103″ platform to platform. Does OSHA require this ladder to be caged?  What is the required distance between the platform and the bottom of a ladder cage?

Q: Is signage required when using lasers?

A: Yes, OSHA States in 1926.54(d) Areas in which lasers are used shall be posted with standard laser warning placards.

Q: We have the Companion Therapy Laser and I was hoping you could inform me on the OSHA safety regulations for this class 4 laser?

A: OSHA does not have any regulations that specifically pertain to this piece of equipment. However, there are a few standards that OSHA could use for citations. 5(a)(1), the general duty clause is used when there is no regulation for a particular item, and states that employers are obligated to provide employees with a safe and healthful workplace.

Q: Are we required to hang the LOTO procedure on all machines or just the ones that are hard wired? Also, if we LOTO even for the plug-in machines, are we required to hang the procedures on those machines as well?

A: OSHA requires that the machine procedures be documented but they do not required that they are posted at the machines. We strongly recommend this as a best practice so the information is readily available for all authorized employees. If you choose to keep the machine procedures for cord and plug operated equipment in place then we would also recommend posting the machine procedures so the information is readily available.

Q: We have a bunch of machines that are same. The only differences are some of the disconnects are in a panel box and some are breakers on the wall. Can we have one LOTO procedure for all of them or do we need to have separate procedures?

A: Due to the differences in the disconnects there will need to be separate procedures. Please contact Lancaster Safety to discuss further.

Q: Are E-Stops required for all machines?

A: According to OSHA, E-Stops are not required on all machinery. They encourage the use of E-Stops, but do not allow them to be used instead of machine guarding or lockout/tagout purposes. This OSHA article that has good information on machine guarding and emergency stops.

Q: What would be considered the lockout device for an air hose – the disconnect to the air hose or the power to the air compressor?

A: You would want 2 lockout/tagout devices, one that controls the power to the air compressor as well as the air hose. Attached is a machine procedure that you can fill out, this will outline the exact steps employees should follow to control the device before work is done.

Q: Where should LOTO equipment be kept?
A: The LOTO equipment should be readily available so that the authorized personnel may obtain their lock and tag to properly de-energize the machine. All authorized personnel shall know where the equipment is being stored.

Q: Where should LOTO equipment be kept?

A: The LOTO equipment should be readily available so that the authorized personnel may obtain their lock and tag to properly de-energize the machine. All authorized personnel shall know where the equipment is being stored.

Is maintaining the highest level of safety easy?  Will you be able to think of all the hazards your workers may face?  Probably not, as no one can think of everything.

Thankfully, we can benefit from the safety community’s collective body of knowledge with the help of OSHA’s annual list of the Top 10 Most Frequently Cited Standards.

Review the list and ask yourself, did you violate any of these?

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

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

Q: When we have to change a skill saw blade onsite, we obviously would unplug the tool but, do we need to have a lock out tag out box to clamp around the plug end so that no one can plug the item back in while it is being swapped out?

A: Other than unplugging the piece of equipment nothing else needs to be done to change the blade in the saw.  OSHA’s 29 CFR 1910.147 standard goes over the requirements that are required for the control of hazardous energy (lockout/tagout). Th…

Q: What are the general requirements for machine guarding?

A: There are a few general requirements for machine guarding that would apply to all machinery: Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible.o The guard shall be such that it does not offer an accident hazard in itself. The point of operation of machines whose operation exposes an employee to injury, shall be guarded.o The guarding device shall b…

Q: Would you be able to let me know what type of machine guarding would be recommended?

A: According to the OSHA regulation, 1910.212(a)(1) Types of Guarding. One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are-barrier guards, two-hand tripping devices, electronic safety devices…

Q: Are E-Stops required for all machines?

A: According to OSHA, E-Stops are not required on all machinery. They encourage the use of E-Stops, but do not allow them to be used instead of machine guarding or lockout/tagout purposes. This OSHA article that has good information on machine guarding and emergency stops.

Q: Can you slow down a press brake enough so that you don’t need guarding?  A: No you can not slow the cycle down to the point that there would not be a need for guarding. A hazard still exists at any speed.

Q: We have a moving mixing pot that has moving parts; does it need to be guarded? (They have had an employee break their arm from it)

A: Yes, the moving parts on any machine needs to be guarded to prevent employees from coming in contact with them.

Is maintaining the highest level of safety easy?  Will you be able to think of all the hazards your workers may face?  Probably not, as no one can think of everything.

Thankfully, we can benefit from the safety community’s collective body of knowledge with the help of OSHA’s annual list of the Top 10 Most Frequently Cited Standards.

Review the list and ask yourself, did you violate any of these?

Q: What are the hazards associated with wearing neckwear encircling the neck or jewelry near machines having rotating shafts or spindles?

A: In the Hand and Power Tools publication, paragraph (f) section (12) it states: “Wear proper apparel for the task. Loose clothing, ties, or jewelry can become caught in moving parts.” In the Basics of Machine Guarding publication, the last paragraph of chapter one states: “Jewelry such as bracelets and rings, can catch on machine parts or stock and lead to se…

Q: When using a wire wheel on a pedestal grinder, do you have to have guarding or tool rest as if it were an abrasive wheel?

A: Yes, you must have the same guarding and tool rest as if it was just an abrasive wheel when using a wire wheel.

Q: Do I need to have a horn for my overhead crane and should my employees wear hard hats? Do I need a checklist for performing work in the forklift man basket?

A: Yes your employees should wear hard hats as the crane creates an overhead hazard, which could result in falling objects. The crane does not need a horn and OSHA does not require the documentation of an inspection of the man basket but I recommend that you use one in case of an OSHA inspection.

Q:  Can we attach a man basket to the forklift? Also, can it be moved while an employee is in it?

A:  OSHA permits the use of personnel platforms on forklifts as long as the manufacture approves it.  You would need to contact the manufacturer of the forklift to see if they permit it’s use.  The manufacturer would also be able to provide you with the new forklift specifications (center of gravity, weight limit, etc.) when using the platform.  Riding on a forklift is not p…

Q: Are man baskets allowed by OSHA?

A: Forklift man baskets are allowed by OSHA as long as you use them the correct way the manufacture designed them to be used.  When employees are inside the man basket they need to have a fall arrest harness on and tied off with a lanyard to ensure they cannot be ejected. Our clients can ask us questions like this any time!

Q: Can you attach a man basket on a forklift that is manufactured by a different company?

A: You must have the manufactures approval when using any attachment on the forklift.  It will vary forklift to forklift, so you will need to contact the forklift manufacture for an answer.

Q:  What is required by OSHA for man lifts as far as fall protection?

A:  If you’re using scissor lifts a personal fall arrest harness is not needed if all four sides of the lift are protected by guardrails since they fall under OSHA’s scaffolding regulation.  If you’re using an extendable boom aerial lift then personal fall protection is required.  It’s OSHA’s policy that an employer will be in compliance with OSHA’s fall protection requirements for aerial lifts if one of the…

Q: Is there an actual OSHA requirement relating to a forklift mounted man basket?  If not, what other “rules” apply to this type of equipment?

A: There is not an actual general industry standard concerning mounted man baskets on forklifts.  However companies must abide by The American National Standards Institute (ANSI).  ANSI’s standard regarding mounted man baskets on forklifts is B56.6.  In this standard it covers the design, training, and machine requirements.  Listed…

Q: Do our operators for the man lift need to be certified? Also, what should the training entail?

A: OSHA’s standards state that only an authorized/competent person shall operate the man lift or aerial device. Therefore…

Q: What kind of certification if any is needed to operate a manlift? Is there special certification needed?

A: OSHA does not require a certification for manlift operation but employees are required to be adequately trained on the equipment. This includes equipment specific training, safe operating procedures, and fall protection. It’s recommended to contact the manufacturer as they have expert knowledge on the equipment.

Q: Who is allowed to operate an overhead crane in a manufacturing facility?

A: See applicable standards below. NOTE: OSHA has separate standards for construction cranes.

1910.179(b)(8)

Designated personnel – Only designated personnel shall be permitted to operate…

Q: Do I need to have a horn for my overhead crane and should my employees wear hard hats? Do I need a checklist for performing work in the forklift man basket?

A: Yes your employees should wear hard hats as the crane creates an overhead hazard, which could result in falling objects. The crane does not need a horn and OSHA does not require the documentation of an inspection of the man basket but I recommend that you use one in case of an OSHA inspection.

Q:  Do we need to barricade off the area underneath an aerial lift?

A:  OSHA’s regulations do not specifically state that the area beneath an aerial lift needs to be barricaded off.  However, it is best to do so.  Tools or equipment could accidentally fall out of the lift and strike someone on the ground causing serious injury.  A hard hat only provides minimal protection.

We recommend having one of our qualified safety consultants evaluate your work site in order to determine best practices for your company.

Q: If I use a powered tool, such as a 110v drill, in their shop, do I need to use a GFCI in the circuit?

A: GFCIs are not required to be used in all outlets in general industry. However…

Q: How often do our power industrial truck operators need to be re-evaluated? Also, is there a different between a lift truck certification and tow motor?

A: For your question regarding Power Industrial Truck training, an evaluation of the operator’s performance is required to be conducted at least once every three years.  The training is to consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, video tape, written material), practical…

Q: What are the proper cleaning procedures for respirators?

A: OSHA requires employers to follow the cleaning procedures found in Appendix B-2 of…

Q: Is it required to keep documentation on filter changes for respirators?

 A: It is not required by OSHA, but it would be a recommendation to keep track of the service-time-limit…

Q: Is obtaining medical clearance for employees who wear respirators a voluntary program? and does it need to only be done once?

A: Medical clearance for employees who wear respirators is mandatory. Additionally…

Q: Should employees who decline to use respirators on a voluntary basis sign a declination form?

A: Yes, although it is not required it would be recommended to reduce future liability.

Q: Can employees share negative pressure respirators?

A: Yes, employees are allowed to share respirators however it is not recommended.  You would have to ensure that the respirators are the same make, model, and size, and that they are sanitized before each different employee uses them.

Q. What are the requirements for voluntary use of respirators?

A. The following is necessary (1) medical clearance; (2) provide employees with information in Appendix D of the OSHA respiratory standard; (3) ensure that respirators are cleaned, stored, & maintained so that they do not present health hazards to users.  To learn more about OSHA compliance look to the experienced consultants at Lancaster Safety Consulting, Inc.

Q: How often are medical evaluations required to be performed?  The health care company said they need to be completed every year.  We thought it was every two years.  Can you clarify?

A: OSHA doesn’t require the medical evaluations to be performed annually or biannually.  Instead, OSHA’s requirements for additional evaluations are as follows:If the employee reports signs or symptoms that are related to the ability to use a respiratorIf the physician, supervisor, or program ad…

Q: Do respiratory medical release forms/respiratory fit tests need to be completed yearly?

A: The Respiratory Medical Release Forms do not need to be completed yearly they just need to be completed once and then again if something changes to their health such as drastic weight gain/loss or a physical change to their face that would affect respirator usage.  The respirator fit tests on the other hand do need to be completed yearly.

Q: How do you know from the MSDS if you need to wear a respirator when working with chemicals that requires a respirator but only at a certain PEL?

A: You cannot tell from just the MSDS. Our recommendation would be to conduct air monitoring to determine what the exposure for the workers would be. If you can’t have air monitoring conducted, you’ll need to assume that the workers are exposed above the permissible exposure limits and follow the MSDS’ recommendation for respiratory protection.

Q: Do employees need re-evaluation of medical clearance for respirator use?

A: Yes, under certain circumstances:1910.134(e)(7) Additional medical evaluations. At a minimum, the employer shall provide additional medical evaluations that comply with the requirements of this section if:         i. 1910.134(e)(7)(i) An employee reports medical signs or symptoms that are related to ability to use a respirator;       ii.

Q: Do medical evaluations need to be conducted annually for respirator wearers?

A: No, additional medical evaluations need to be conducted if:An employee reports medical signs or symptoms that are related to ability to use a respirator A PLHCP, supervisor, or therespiratory program administrator informs the employer that an employee needs to be reevaluated. Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation; or A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.

Q:  An employee assigned to clean out a furnace insisted that OSHA requires him to wear a respirator while cleaning out the furnace.  Do we have to provide it and what kind of respirator do we need?

A:  In order to determine if a respirator is needed air monitoring must be conducted to figure out the amount of exposure. If the exposure is over OSHA’s Permissable Exposure Limit (PEL) then controls need to be used to reduce the exposure. The type of respiratory protection would be based off of the amount of exposure and the substance.

Q: Do employees who voluntarily wear dust masks still need to sign Appendix D?

A: If you have any employee who voluntarily wears a dust mask, then they must review and sign Appendix D.

Get your safety questions answered today by contacting us at (724) 776-1003.

Q:  When are medical clearances and fit tests required?

A: Since they are not working with lead the medical clearances are required initially and only if the employee had a major health concern (gained weight, heart attack, etc). They fit tests are required yearly.

Q: Can you use a 15 foot warning line on when preforming HVAC work on a low sloped roof?

A: Here is a interpretation from OSHA that reviews this warning line regulation. As you can see they do state the use of the 15 foot warning line but it is still referred as a De Minimis Violation.

Q:  Are there restrictions or requirements regarding the use of gas powered 4 wheel carts on a roof?  The carts would be driven.  The brakes are normally cable drum brakes.  The specific job we are referring to would have 2’ high parapet walls.  Please advise to the perimeter safety requirements.

A:  Since the parapet wall is only 24” high OSHA wouldn’t consider this adequate fall protection.  In order for the parapet wall to meet OSHA’s guardrail requirement of 42” (plus or minus 3”) it would need to be 39-45” high.  If you extend the height of the parapet wall to meet OSHA’s guardrail requirements, you can operate the cart freely on the roof.  That’s assuming the parapet wall fully encompasses the roof and your employees wouldn’t be exposed to an area where the guardrail height wouldn’t be below 39”.

Q:  Does OSHA have a defined wind speed where roof work should be stopped.

A:  Unfortunately, OSHA does not have a defined wind speed.  OSHA only mentions “high winds” in the regulations.  The responsibility to remove workers from the roof is given to the employer.  Ultimately it comes down to the supervisor on the job to stop the work once it is determined the wind is creating a dangerous situation for the workers.

Q: In construction, is it acceptable to tie off to roof carts that weigh about 500 lbs.?

A: No. The anchor point should not be mobile and should follow the guidelines of 29 CFR 1926 Subpart M:
1926.502(d)(15) – Anchorages used for attachment of personal fall arrest equipment shall be independent of any anchorage being used to support or suspend platforms and capable of supporting at least 5,000 pounds (22.2 kN) per employee attached, or shall be designed, installed, and used as follows:
1926.502(d)(15)(i) – as part of a complete personal fall arrest system which maintains a safety factor of at least two; and
1926.502(d)(15)(ii) – under the supervision of a qualified person.

Q: During construction, when covering openings in a roof such as skylights and fan rough-ins, how strong does the material have to be?

A: 1926.502(i)(2) All other covers shall be capable of supporting, without failure, at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time.

Q. How far away from a building does a 1000 gallon Propane tank need to be, according to OSHA?

A. A propane tank with anywhere between 500 gallons up to 2000 gallons needs to be kept…

Q: When we install hard perimeter safety, does our company have the right to deny other trades, architects, and other third party individuals from entering our work area without an escort from our company, or participating in our safety course prior?

A: You do have the right to escort or have personal go through your safety training prior to them entering the area that you have installed perimeter safety. This is recommended as a best safety practice. Also, if using a ladder to gain access…

Safety is a word that can evoke a variety of thoughts and emotions. To company leaders, the word could mean “something that is not worth my time” to “an important investment in my company’s future.” It is this second group of likeminded business owners and CEOs that truly get the meaning of safety and take it to the highest level at their companies.If you’re wondering how safety could possibly be at the forefront of a company executive…

Scaffolding Horror Stories, By: Jack Rubinger, Graphic Products: Scaffolding safety is on OSHA’s radar year after year. According to OSHA, an estimated 2.3 million construction workers, or 65% of the construction industry, work on scaffolds frequently. Protecting these workers from scaffold-related injuries would prevent 4,500 injuries and 50 deaths every year, at a savings for American employees of $90 million in workdays not lost. For those in the construction, painting, and window was…

ASSE Fellow Award: Congratulations to our OSH Consultant, Gary Barnett, for being honored by The American Society of Safety Engineers (ASSE ) and receiving their Fellow Award! The Fellow Honor according to ASSE is “the Society’s most prestigious honor, recognizing a lifetime of commitment to worker safety and health. Each Fellow recipient has had a wealth of unique personal…

“We’ve never had an accident.” It is a sentence we hear all the time. It is a similar argument to car insurance and health insurance. “I’ve never wrecked my car,” or “I don’t have major health issues,” do not always win the argument for not having car and health insurance. After a prolonged period of time with things going smoothly, we get a false sense of security that nothing bad will happen. We can feel invincible (like an elephant walking on a tightrope). Unfortunately, that seems to be about the time an accident happens…

An effective Safety Committee has a significant impact on health and safety throughout the organization’s culture, and may also save the company money through reduced workers’ compensation costs, fewer lost workdays, and increased productivity due to higher employee morale. What’s The Point?  The purpose of a safety committee is to reduce the risk of workplace injuries & illnesses, inform and educat…

Online training is appealing to managers and supervisors because it can usually be completed at the employees’ convenience with little to no scheduling or travelling involved. The employees can sit in a comfortable setting where they can easily see the presentation. The biggest perks to online OSHA trainings are the convenience and cost-effectiveness when training only one employee or just a few employees.

Q: Since we are doing our own sandblasting, we are getting our sandblaster an air supplied respirator / blasting helmet. If he is more comfortable in the air supplied full face respirator will that be OSHA compliant or do we need to get him the air supplied blasting hood?

A: OSHA requires that employees must be protected by an abrasive-blasting respirator approved by NIOSH.

Q: We have a machine that is about 8-10 feet in the air and the employees work on top of it. Do they need to be tied off?

A: If an employee is exposed to a drop greater than 4 feet, fall protection must be provided. In this instance, there could be a restraint attached to the machine that they could tie off to. Guard rails could also be used if feasible as well as a rolling ladder or scaffolding.

Scaffolding Horror Stories, By: Jack Rubinger, Graphic Products: Scaffolding safety is on OSHA’s radar year after year. According to OSHA, an estimated 2.3 million construction workers, or 65% of the construction industry, work on scaffolds frequently. Protecting these workers from scaffold-related injuries would prevent 4,500 injuries and 50 deaths every year, at a savings for American employees of $90 million in workdays not lost. For those in the construction, painting, and window was…

Q: If you lower a Perry scaffolding to the lowest point, which is 26 inches off the ground, do you need an access ladder?

A: OSHA’s scaffolding requirement is anything over 2 feet or 24 inches you need a means of safe access. This does not mean it has to be a ladder an approved stool would be sufficient.

Q: Do employees have to use the ladder to access scaffolding on the jobsite.

A: Yes the employees should use the ladders to access scaffolding. OSHA standard on ladder access to scaffolding is :

1926.451(e)(1)

When scaffold platforms are more than 2 feet (0.6 m) above or below a point of access, portable ladders, hook-on ladders, attachable ladders, stair towers (scaffold stairways/towers), stairway-type ladders (such as ladder stands), ramps, walkways, integral prefabricated scaffold access, or direct access from another scaffold, structure, personnel hoist, or similar surface shall be used. Cross braces shall not be used as a means of access.

Is maintaining the highest level of safety easy?  Will you be able to think of all the hazards your workers may face?  Probably not, as no one can think of everything.

Thankfully, we can benefit from the safety community’s collective body of knowledge with the help of OSHA’s annual list of the Top 10 Most Frequently Cited Standards.

Review the list and ask yourself, did you violate any of these?

Q: Do all employees need to be certified as a competent person?

A: No, OSHA only requires that one employee be qualified as a competent person. All other employees need to be trained by a qualified person on the noted requirements if they perform work while on a scaffold (1926.454(a) or are involved in erecting, disassembling, etc. (1926.454(b).

Q: When using scaffolding, what safety measures need to be taken to stay safe when working by secondary electric lines running to homes or businesses?

A: You have several options that you can use to keep yours employees safe, as well as being in compliance with OSHA:You can disconnect the powerWork at least 10 feet from the linesReroute the linesHave the power company cover the lines.

Q: Does an employee have to wear a fall arrest harness when working in a scissor lift, also can we move the scissor lift?

A: The employee does not have to wear a fall arrest harness if the scissor lift has adequate fall protection. (standard railing) Also the scissor lift can’t be moved with a person in it while the lift is elevated. The employee must lower the lift, reposition then raise lift to continue the work.

Q: Is it acceptable to use a scissors lift from an elevated platform that has perimeter openings of 40 inches around the outside of the floor?

A:  Since the wall openings are 40 inches, it is required for workers working from the floor level to have fall protection.  In this case the horizontal lifeline and fall arrest harnesses are acceptable, as long as they are used in the proper form.  Any employee using the scissors lift will be required to have their fall arrest harness secu…

Q: Are employees required to be tied-off when working on a guardrail-equipped scissor lifts?

A: No, OSHA does not require employees to be tied-off when working from scissor lifts that have properly maintained guardrails.

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

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

Q: Do you need to wear a fall arrest harness when working in a scissor lift that that has a guardrail system around it?

A: No, you do not need to wear a fall arrest harness when working in a scissor lift if it has a proper guardrail system around it.  However, if the guardrail system is less than adequate, or the worker leaves the safety of the work platform, an additional fall protection device would be required.

Q:  Do you have anything on training for skid steer authorization?

A:  Since skid steers are considered “earth removal equipment” they do not fall under the scope of OSHA’s powered industrial truck requirement.  However, if the skid steer does have a vertical mast it would fall under the requirements.  Click here for an OSHA standard interpretation on this subject.  Although OSHA doesn’t have any training requirements for this type of equipment it is still highly recommen…

Q: Can the employees wear slicker boots, is there a tripping hazard associated with them?

A: Yes the employee can wear slicker boots to prevent the water from soaking the employees, there are no OSHA items stating that they are a potential tripping hazard.

Q: What does OSHA allow for a pitch of a ramp and does it need hand rails?

A: OSHA does not want a ramp greater than 30 degrees from horizontal and it must have a handrail if it is 20 degrees or more.

Q: Are steel toed shoes required for forklift operators, warehouse personnel, or anyone that interfaces with forklift traffic?

A: In essence, if a work environment or job site potentially contains a “danger of foot injuries” due to falling, rolling or piercing objects, then steel toed shoes should be…

Q: We manufacture and paint steel windows and doors. The raw materials are heavy and the finished product is very heavy. Should we be requiring our employees to wear steel-toe or composite-toe boots?

A: According to the OSHA Personal Protective Equipment standard…

Q: When do employees need to replace their steel toed shoes?

A:  Whenever the boots themselves would present a hazard; such as the soles falling apart, etc.  They would also need replaced if the steel is damaged in any way because they would not work properly in the time of need.

Q:  Can we attach a man basket to the forklift? Also, can it be moved while an employee is in it?

A:  OSHA permits the use of personnel platforms on forklifts as long as the manufacture approves it.  You would need to contact the manufacturer of the forklift to see if they permit it’s use.  The manufacturer would also be able to provide you with the new forklift specifications (center of gravity, weight limit, etc.) when using the platform.  Riding on a forklift is not p…

Q: If we have a 2-day construction project, do we need to do a toolbox talk each day?
A: OSHA does not require toolbox talks, although they do encourage them.  Safety meetings are always a good way to keep your employees thinking about safety, which is always helpful.  On a two day job it would probably be ok to just hold one meeting, unless the work you are doing is completely different on the second day.

Q: What is the proper way to load a tractor trailer that is disconnected from the truck?

A: According to OSHA’s regulations he must set the brakes and wheel blocks to prevent movement of the trailer. Also if necessary, fixed jacks may be put into place to support a semitrailer during loading or unloading when the trailer is not connected to the truck.

Q: I have a trench that is currently 6 feet high on both sides.  I want to adjust it so that a protective system does not have to be used.  If I adjust it to be four feet, will I need a protective system?

A: For trenching, a protective system is required for a trench 5 feet deep or greater.  Therefore, if you would adjust your trench to make the edges only four feet high, a competent person may determine that a protective system is not required.

Q: Are you permitted to dig 1-2 feet below the shoring box in a 4×5 trench?
A: Yes, according to 1926.652(e)(2)(i), you can excavate no more than 2 feet below the bottom of the support system, only if the support system itself can handle and resist the forces calculated for the full depth of the trench and if there are no signs of a loss of soil from below or behind the support system…

Q: Can I mount plates to the end of our trench boxes to further prevent cave-ins?

A: That may be acceptable, however you will need to verify and be able to prove that any modifications are properly engineered to withstand the anticipated pressure that will be applied.  This can be accomplished by requesting approval from the manufacture or an accredited engineer, however it may be best to purchase a new box instead.

Q: Can the employees wear slicker boots, is there a tripping hazard associated with them?

A: Yes the employee can wear slicker boots to prevent the water from soaking the employees, there are no OSHA items stating that they are a potential tripping hazard.

Q: If employees are working approximately 25 feet from welding operations, is it required that welding curtains be used?

A: OSHA does not give a definitive working distance, but states that proper welding shields or curtains shall be used to protect other workers in the area. (1910.152(b)(2)(iii)).

Q: Employees were welding on Hastelloy (Nickel based) and it’s moving more towards a production level. Do they need to be wearing respirators?

A: Yes, employees do have the potential for exposure to Hex Chrom…

Q: We have a weld joint that needs to be “fused” after machining.  The welder reaches into a 16” opening about 18” deep and welds this circumferential weld.  His feet never leave the floor; but his head is in the opening.  Based on OSHA’s definition of “entry” do we need to be concerned about this being considered a confined space?…

Q: Do you have to have a certified welder to weld the cross beams on a crane?

A: OSHA does not say anything about the need for a certified welder it just says the welder must be qualified.  When welding on a crane though, you need to contact the crane manufacture to get their approval because welding on the crane can affect the load rating of that crane.

Q: If you only have one oxygen cylinder on a welding cart do I have to follow the 1910.253 (b)(4)(iii) storage requirement?

A: For general industry, as long as the oxygen tank is “in use” or “connected for use” the storage requirements do not apply.

Q: “Can I have the Temp Agencies go over safety information with the temporary employees before they actually come here and work? If so what would they need to go over?”

A: OSHA views temporary workers as if they were exiting normal employees. Temporary staffing agencies and host employers share control over the employee, and are therefore jointly responsible for temp employee’s safety and health…