NEWS & VIEWS

FEDERAL OSHA TOP 10 CITED STANDARDS, FY 06-07

In the manufacturing (General) industry, for fiscal year 2006 - 2007, OSHA cited facilities most frequently for the following standards and sections:

• 1910.212 - General machine guarding
• 1910.1200 - Hazard Communication Written Plan
• 1910.212 - Point of Operation Guarding
• 1910.147 - Lock Out / Tag Out Written Plan
• 1910.1200 - Hazard Communication Training
• 1910.147 - Lockout /Tag Out annual audit/periodic inspection
• 1910.147 - Lockout /Tag Out procedures
• 1910.132 - PPE certification of hazard assessment
• 1910.147 - Lockout / Tag Out training
• 1910.23 – Guarding of open-sided floors over 4 feet


INJURY AND ILLNESS POSTING REMINDER

By the time you are reading this article, you should have already posted your company’s OSHA Form 300A, the summary of the total number of job-related injuries and illnesses occurring during 2007. This posting must remain in place until April 30, 2008.

Of course, if your company employs ten (10) or fewer employees you are exempt from the posting regulation. Other companies in certain industries may also be exempt from OSHA’s recordkeeping and posting requirement.


OSHA ISSUES HEX CHROME ENFORCEMENT PROCEDURES

OSHA issued new enforcement procedures for its inspectors in regard to the hexavalent chromium Cr(VI) exposure standards that became effective back in May 2006. This enforcement directive became effective January 24, 2008.

The Cr(VI) standards applied within a six-month period to employers with 20 or more employees, while employers with fewer than 20 employees were given 12 months to comply with most of the provisions. All employers are allowed four (4) years from the effective date to install feasible engineering controls.

Essentially, OSHA’s new directive provides a roadmap for its field inspectors to complete Cr(VI) inspections for those employers that are regulated by 29 CFR 1910.1026, 1926.1126, and 1915.1026. The new enforcement procedures include a review of the employer’s air sampling records to determine exposure levels; guidance on how employers can implement engineering and work practice controls to reduce and maintain employee exposure below PELs; employer requirements to provide hygiene areas for employees; guidelines for employer maintenance of exposure and medical surveillance records; and other requirements.