• General Duty Clause.

1. Record Keeping – 29 CFR 1904 is the process for entering information on the OSHA 300 Log documenting employee illness or injury. For any injury or illness to be recorded on the log it must be a new incident, work-related and serious enough to meet the general recording criteria or the application to specific cases. An accident or injury is recordable if it meets any of the following: Death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid or loss of consciousness.

Record keeping is OSHA’s way of tracking statistics, so the agency is fussy about getting the information the way it wants it. They don’t want documentation of every accident that you would notify your workers’ compensation carrier of, which is a common mistake. They only want logged the incidents that meet the above requirements. Therefore, whoever is in charge of keeping your OSHA 300 Log should be aware of what should or should not be on the log.

As a side note, the OSHA 300 Log is an excellent tracking tool to help your operation set and achieve safety goals. For example, with statistics from the OSHA log, your company can benchmark against the industry’s incident rate.

2. Lockout/Tagout: Also known as the Energy Control Program, 1919.147 refers to specific practices and procedures to safeguard employees from the unexpected startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities.

This rule is not limited to electrical equipment. It also includes chemical, steam, air, hydraulic and other energy sources. In 2006, across all industries, there were 2,291 lockout/tagout related violations that resulted in initial penalties of more than $3 million.

To be in compliance, operators need to be aware of the requirements of the Energy Control Program, which include the following:

Training and Communication that includes the following classification of employees: Authorized, Affected, Other.

Periodic Inspections — 1910.14 (c) (6). This covers inspection policies and should be done at least once a year. This is also a great opportunity for retraining authorized employees.

3. Hazard Communication (HazCom) Standard: The Right to Know Law, 1910.1200, directs that employees have a right to know what chemicals they are working with or around. The intention is to make the workplace safer. The five principal components of the Haz-Com standards are:

• Chemical inventory must be completed and current;

• Material Safety Data Sheets (MSDSs) must be complete and current;

• Labeling program must encompass every container;

• HazCom program must be in writing;

• HazCom training is mandatory for all affected employees, including migratory employees.

4. Machine Guarding, 1910.212 is to protect the machine operator and other employees in the work area from hazards created by ingoing nip points, rotating parts, flying chips and sparks. Some examples are barrier guards, light curtains, two-hand operating devices, etc.

A good rule to remember is any machine part, function or process that may cause injury must be safeguarded. When the operation of a machine or accidental contact with it can injure the operator or others nearby, the hazards must either be controlled or eliminated.

5. Electrical installation standard, 1910.301 to 1919.399, focuses on safety in the design and installation of electric equipment in the workplace. This addresses electrical equipment in the workplace. This addresses electrical safety requirements that are necessary for the practical safeguarding of employees in their workplaces and is divided into four major divisions:

• Design safety standards for electrical systems;

• Safety-related work practices;

• Safety-related maintenance requirements;

• Safety requirements for special equipment.

6. Material handling, 1910.176 and 1910.178, is a vital part of many industries that are labor intense. OSHA CFR 29 1910.176 states, “Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repair, with no obstruction across or in aisles that could create a hazard. Permanent aisles and passageways shall be appropriately marked.”

The other part of this topic is 1910.178 and deals with powered industrial trucks, like forklifts. Operators must have both formal instruction and practical training. Drivers must successfully complete the training and an evaluation before they are allowed to operate an industrial truck without direct supervision.

7. Bloodborne Pathogens, 29 CFR 1910.1030 covers all employees who could “reasonably anticipate,” as a result • Safety requirements for special equipment.

6. Material handling, 1910.176 and 1910.178, is a vital part of many industries that are labor intense. OSHA CFR 29 1910.176 states, “Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repair, with no obstruction across or in aisles that could create a hazard. Permanent aisles and passageways shall be appropriately marked.”

The other part of this topic is 1910.178 and deals with powered industrial trucks, like forklifts. Operators must have both formal instruction and practical training. Drivers must successfully complete the training and an evaluation before they are allowed to operate an industrial truck without direct supervision.

7. Bloodborne Pathogens, 29 CFR 1910.1030 covers all employees who could “reasonably anticipate,” as a result of performing their job duties, to come into contact with blood and other potentially infectious materials. This could include route drivers who pick up soiled linens, hospital workers, janitorial staff and others.

As an employer, if your people handle any healthcare items or have a trained first-responders team, you have to assess exposure determination by job classification. The core categories of this standard include the following:

• Development and implementation of a written exposure control plan;

• Implementation of the concept of the universal precautions;

• Implementation of engineering, work practice administrative and PPE controls;

• Offering hepatitis B vaccinations;

• Initiate housekeeping practices;

• Training all employees covered by the standard;

• Follow up on all exposure incidents;

• Record needle sticks and cuts from sharps on OSHA 300 Log.

8. Personal Protective Equipment, 1910.132 requires the use of personal protective equipment to reduce employee exposure to hazards when engineering and administrative controls are not feasible or effective in reducing the exposure to acceptable levels.

Employers are required to determine if PPE should be used to protect their workers. Hazards to beware of include handling chemicals, welding and cutting or brazing.

9. Confined Spaces, 29 CFR 1910.146 defines a confined space as:

• Large enough and so configured that an employee can enter and perform assigned work;

• Limited or restricted means for entry or exit (for example: tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry);

• Not designed for continuous employee occupancy.

The following criteria require an area to have a confined-space permit:

• Contains or has a potential to contain a hazardous atmosphere;

• Contains a material that has the potential for engulfing an entrant;

• Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a small cross-section;

• Contains any other recognized serious safety or health hazard.

10. General Duty Clause, Section 5 (a)(1) of the Occupational Safety and Health Act, provides that every employer shall furnish to each employee a place of employment “free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees.”

Just because there may be no specific regulation covering an area of your facility, does not mean OSHA cannot cite a facility for failing to provide its employees with a workplace that is free from safety and health hazards.