Guarding Floor and Wall Openings (29CFR1910.23)

Last week we discussed Walking-Working Surfaces. In this standard (OSHA 1910.21), OSHA discusses the basics of Walk-Working Surfaces, primarily focusing on what is required to protect employees from injury while negotiating the work place. This includes everything from hand and guardrails to grab bars and toe boards. Each of these safety requirements also have their own standard. For most, and those which are most commonly an injury risk, standard 1910.23 explains the requirements set by OSHA.

Standard 1910.23 discusses the specifics of railings, toe boards, coverings, and guards for floor and wall openings. This includes dimensions, clearance, materials they are made of, required strength, locations, construction, and anchoring of these floor and wall opening guards. It also discusses applicable signage, maintenance, and upkeep required.

Many customers we meet with don’t realize that this standard relates to them; floor and wall openings are not just the rough openings at construction sites or openings related to large industrial facilities. Per OSHA, these openings range from stairwells and ladders to skylights, chutes, and hatchways. If your place of business has any of these, it might be worth a second look at the guarding you have in place. And it should certainly be a part of your annual safety audits.

If you have any questions about the guards for floor and wall openings at your company, please contact us so we can help you guarantee that you have a safe worksite for all of your employees. And if you have anything to add about guarding for floor and wall openings, please leave a comment.

Hand Tools and Equipment (29CFR1910.242)

Hand tools and portable powered tools and their equipment are a necessary part of most businesses. And as such, most employers purchase the tools used by customers and employees. If your business is one of the many who fall into these categories, then OSHA is watching you. They enacted Standard 1910.242 to enforce proper safety procedures are being followed in regards to these dangerous tools.

Though small and general, this standard can be crucial to any business using these types of tools. It sets a requirement that “each employer shall be responsible for the safe condition of tools and equipment used by employees, including tools and equipment which may be furnished by employees.” (1910.242[a]) But how do you know what is considered “safe condition?” Well, that is determined by a number of organizations, including OSHA and ANSI. Each type of tool has different requirements, and you need to cross reference each type of tool with the various standards applicable to them. For some, it is quite simple to find the relevant standards; for others, it is not so easy.

Standard 1910.242 also discusses the use of compressed air for cleaning machinery. Any use of compressed air is prohibited unless the pressure is kept below 30 p.s.i. and proper chip guarding and personal protective equipment is utilized.

If your company uses hand or portable powered tools, you need to ensure you are compliant with Standard 1910.242. In order to ensure compliance, it is recommended you have a third party safety audit so that your machinery and procedures are properly reviewed. If you have any questions, please contact us. And if you have anything to add about properly maintaining hand tools and portable powered tools, please leave a comment.

HAZWOPER (29CFR1910.120)

Hazardous waste is not a subject to be taken lightly. Improper handling of hazardous waste at any point from transportation to storage to disposal can lead to serious and potentially lethal consequences for the handlers of the waste material. Because of the serious nature of hazardous waste, OSHA takes your company’s hazardous waste operations very seriously. As a result, standard 1910.120, dubbed HAZWOPER (short for hazardous waste operations and emergency response), was created. This standard covers the cleanup, transportation, storage, handling, and disposal of all hazardous waste materials.

HAZWOPER needs to be an integral part of the Emergency Action Plan for any company which deals with hazardous materials. The HAZWOPER plan should include the policy for reporting hazards to the safety and management teams, as well as any applicable state or local authorities. Further, this plan needs to discuss who is permitted access the hazardous areas and the locations where hazardous materials are stored, the frequency with which these team members have access, the medical screenings performed, the regularity of the screenings. It also needs to discuss in detail the containment devices utilized for the hazardous waste, the transportation procedures for moving the hazardous waste, and the disposal procedures for the waste. There are very clear and well defined procedures for each of these requirements.

If you have any questions about your HAZWOPER procedures, it is important to have a qualified third party review your Emergency Action Plan and audit your workplace. And if you need any help with updating or instituting your procedures, please contact us. If you have anything to add about HAZWOPER, please leave a comment.

Walking-Working Surfaces (29CFR1910.21)

It might seem silly, but often the most serious on the job injuries come from slips, trips, and falls. These extremely avoidable injuries are often a red flag for OSHA, who will target your company for a surprise audit. And while many of these injuries are simply employees tripping even though all proper safety precautions have been taken, many other times the issues are actually due to an unsafe workplace. Because of these types of accidents, OSHA created Standards 1910.21-1910.30. These standards lay out the groundwork for what is required of employers on the jobsite to create a safe walking space for both customers and employees.

The standard covers how to properly handle holes and openings in floors, platforms, holes and openings in walls, risers, stairs, ladders, and scaffolds. It specifically designates when handrails, toeboards, baskets, braces, guardrails, grab bars, and other safety devices must be available to customers and employees. It also discusses how these work areas must be signed and protected to make employees and customers aware of potential hazards, and what steps must be taken to help people avoid these areas.

This all seems very obvious, I’m sure, but the technical details of what is required for each potential hazard can be cumbersome to reference, and one incorrect sign or missing grab bar, and it can mean a serious injury or serious fines from OSHA. And even if you think your facility is following the standards set forth by OSHA, it is always important to remember to have your annual safety audit performed, to ensure nothing has changed in the verbiage of the standards.

If you have any questions about the walking-working surfaces at your place of business, please contact us and we can help you to ensure you are up to code. And if you have any personal experiences to relate about this issue, please post a comment.

Flammable Liquids (29CFR1910.106)

Flammable liquids are a unique type of hazardous material. Most companies go to great lengths to protect themselves from other hazardous materials, such as those which are toxic or corrosive, but are often inadequately prepared for the storage, maintenance, and use of flammable liquids. And so, should OSHA come for an inspection, they will immediately be in violation of OSHA Standard 1910.106, which covers the proper handling of flammable liquids.

The standard discusses the tanks used to store flammable liquids. This includes both small cylinders, such as those used for compressed gas like propane, and large ones, such as those which are permanently built inside or outside of a building. It discusses where tanks can be stored, under what circumstances the tanks can be stored, and how often the facility where they are being stored must be audited. Finally, it discusses the actual tanks, including how big they are, what materials they are made of, and what safeguards they must have to be considered up to code.

The standard also discusses the piping, valves, and fittings which are used in conjunction with storage tanks and flammable liquids. OSHA has set rigid guidelines pertaining to what is and is not an acceptable version of each of these items. These guidelines include the designs of these items, materials used for these items, the lining of these items, supports utilized, and testing for these items. One outdated valve on a propane tank, for instance, can lead to a serious problem with OSHA, and an unsafe work environment.

If you have any further questions about flammable liquids or what you can do to ensure you are up to code, please contact us. And if you have anything to add about flammable liquids, please leave a comment.