Powered industrial trucks are used on a daily basis by many companies. Most employers don’t think twice about the trucks after they are purchased, and no employees give a second thought to the safety of a piece of equipment they use every day. Unfortunately, that lackadaisical approach to industrial trucks has lead to countless workplace injuries and OSHA fines. To combat workplace injury around these powerful machines, OSHA instituted Standard 1910.178 which covers the fire protection, design, maintenance, and use of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines (1910.178(1)(2)). So, if you utilize any of these trucks at your workplace, you might want to ensure you are using them properly.

This standard requires that all trucks be used as intended by the manufacturer, with no modifications, and with all preventative maintenance properly performed. If you do modify the trucks in any way, you need to receive written consent from the manufacturer, which ensure the modification does not make the truck unsafe. You also need to ensure any trucks utilized are up to code based upon the American National Standard for Powered Industrial Trucks, Part II, ANSI B56.1-1969. Once you ensure your trucks are approved, you must identify that they have been approved with a label or tag stating their approval. There must also be official markings stating the truck is approved for fire safety purposes based upon the 11 designations defined in OSHA 1910.178. Then, you need to ensure all designations are listed in the correct locations as outlined in the standard.

Next, you need to look at how your trucks are being used. Most trucks have safety guard requirements, based upon the size and type of truck. You also need to consider how the fuel and batteries are handled and stored. Depending upon the type of truck you use, there might also be regulations around the brakes and wheel stops you have in place. Finally, you want to ensure that your operators are fully trained and competent in the use of the industrial truck they are driving.

If you have any questions about this standard and how it relates to particular industrial trucks your company uses, please contact us. Should you have anything more to add about standard 1910.178, please leave a comment.

If you work in an industry that handles hazardous materials, it is important to understand the laws around communicating the potential hazards of said materials. OSHA created Standard 1910.1200, which must be followed when labeling and classifying hazardous materials. And while most companies certainly consulted this standard upon creating their Safety and Health Management System, many have not looked back since. Unfortunately, there was a big update last year which changed this standard to bring it up to code with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals, Revision 3. This was the first major revision since 1994 to this standard, and has left many businesses out of compliance.

This standard is extremely specific about how to classify hazardous materials, how to identify hazardous materials, and how to communicate information and appropriate protective measures regarding hazardous materials to employees. This standard applies to laboratories, wholesalers, manufacturers, importers, warehouses, retail stores, and anywhere else hazardous materials might be found. The standard defines what a hazardous material is, what needs to be on the labels, the types of labels required, and what needs to be communicated to employees. It also explains what needs to be included in the written hazard communication program which you develop for your employees. Finally, it discusses what is not a hazardous material, and when hazardous materials are exempt from all or part of this standard. Because of the complexity of this standard, and how it is situated to uniquely handle many different industries differently, it is important that this is a focal point of your annual third party safety audits.

If you are unsure if you are still up to code given the recent changes, then please contact us so that we can further discuss this standard as it relates to your business. And if you have anything to add about the recent changes to hazard communication guidelines, please leave a comment.

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 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.

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.

If you are in an industry that deals with blood or the potential exposure to blood, protection against bloodborne pathogens needs to be a top priority. OSHA has developed a standard, Standard 1910.1030, which regulates bloodborne pathogens. This standard explains what qualifies as a bloodborne pathogen, what steps need to be taken to prevent exposure, what to do in the event there is exposure, and how to track and monitor exposures. All of this information must be compiled into an exposure control plan.

The first step in prevention is ensuring correct personal protective equipment is worn. For work with blood, this would be gloves, gowns, laboratory coats, face shields or masks, eye protection, mouthpieces, resuscitation bags, pocket masks, or other ventilation devices. Personal protective equipment must not allow blood or other potentially infectious materials to pass through and reach your employees or their clothing. Personal protective equipment is the primary line of defense against the spread of infectious diseases, and must be properly utilized.

In the event there is an exposure incident, there must be a tracking and monitoring process in place. The process must include incident evaluation and medical evaluation. The incident evaluation must include documentation of what happened and how the exposure happened. The medical evaluation must include blood testing and any relevant medical or psychological treatment.

You also need to consider how you properly dispose of waste items, what signage you have, annual audits, training, and how you keep your records. If you have any questions about maintaining an exposure control plan for bloodborne pathogens or the specifics of standard 1910.1030, please contact us. If you have anything to add about bloodborne pathogens, please leave a comment.

When evaluating your safety procedures, it is best to start with your Safety and Health Management System. If you do not have a Safety and Health Management System established for your business, it is crucial to incorporate one. These systems give you a central system to manage all aspects of safety for your business, which helps you to ensure compliance with OSHA.

The core elements of an effective Safety and Health Management System are: worksite analysis; hazard prevention and control; training for employees, supervisors, and managers; employee involvement; and commitment from management. By effectively implementing these elements into your system, they will become a core competency of your business, and thus an integral part of day to day business, ensuring you are consistently compliant.

If these parts are not all currently in your Safety and Health Management System, it is time to update your system. When updating or establishing a system, make sure you start with a serious worksite analysis. It is recommended you do this through a third party audit; professionals can often find hazards that your safety team has overlooked. Many auditing companies will also help you through the rest of the process of establishing a Safety and Health Management System.

If you have any questions about the parts of a Safety and Health Management System, or if you would like some information about an audit to get you started on setting up your system, please contact us. If you have any information you would like to add about Safety and Health Management Systems, please leave a comment.