Workplace Safety Answer Manual Q A J J Keller Associates 2014 PDF

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Workplace Safety Answer Manual
Copyright 2014
J. J. Keller & Associates, Inc.

3003 Breezewood Lane
P.O. Box 368
Neenah, Wisconsin 54957-0368
Phone: (800) 327-6868
Fax: (800) 727-7516
JJKeller.com
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ISBN: 978-1-61099-147-6
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Published & Printed by

J. J. Keller & Associates, Inc.
3003 Breezewood Lane, P.O. Box 368
Neenah, Wisconsin 54957-0368
Phone: (800) 327-6868
Fax: (800) 727-7516
JJKeller.com
publishers ROBERT L. KELLER

JAMES J. KELLER
EDITORIAL
vice president – editorial resources WEBB A. SHAW
director – editorial resources PAUL V. ARNOLD
project editor JENNIFER J. STROSCHEIN
sr. editorial manager – workplace safety PETER M. MCLAUGHLIN
sr. editor – workplace safety J. TRAVIS RHODEN
editor – workplace safety ROBERT A. ERNST
editor – workplace safety TRICIA S. HODKIEWICZ
editor – workplace safety JUDIE SMITHERS
editor – workplace safety MARK H. STROMME
associate editor LISA M. NEUBERGER
sr. metator/xml analyst MARY K. FLANAGAN
sr. layout editor MICHAEL P. HENCKEL
PUBLICATIONS & PRODUCTS

chairman ROBERT L. KELLER
vice chairman & treasurer JAMES J. KELLER
president & ceo MARNE L. KELLER-KRIKAVA
evp & chef operating officer RUSTIN R. KELLER
chief financial officer DANA S. GILMAN
sr. director of product development CAROL A. O’HERN
sr. product development manager JENNIFER M. JUNG
product development specialist ASHLEY C. PUCKER
director of manufacturing TODD J. LUEKE
sr. electronic publishing & prepress manager GERALD L. SABATKE
The Editorial Staff is available to provide information generally associated with this publication to a
normal and reasonable extent, and at the option of, and as a courtesy of, the Publisher.
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Reserved
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Table of Contents
Introduction
Introduction
How to Use This Manual
Still Have a Question?
A Word of Caution
FAQS
Introduction
A
AEDs
Aerial Lifts
Aisles and Walkways
B
Bloodborne Pathogens
C
Compressed Gases
Confined Spaces
D
E
Electric Power Generation, Transmission, and Distribution
Emergency Action Plans
Emergency Eyewashes and Showers
Ergonomics
Exit Routes
Extension Cords
Eye and Face Protection
v
9/14
F/G
Fall Protection
Fire Prevention Plans
First Aid
First Aid Kits
Fixed Ladders
Flammable Liquids
H
Hazard Communication
I/J/K
Injury and Illness Recordkeeping
Inspections
L
Lockout/Tagout
M/N
Machine Guarding
O
P/Q
Portable Fire Extinguishers
Portable Ladders
Powered Industrial Trucks
R
Recordkeeping
Respiratory Protection
S
Scissor Lifts
Spray Booths
Stairs
Storage Racks
vi
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T/U/V
Training
W/X/Y/Z
Reference
OSHA Letters of Interpretation
Glossaries
Agency Contacts
Index
vii
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Reserved
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Introduction
More than 90 million Americans spend their day on the job. For years, no uniform and
comprehensive provision existed for their protection against safety and heatlh hazards.
Finally, the Occupational Safety and Health Act (OSH Act) of 1970 was passed “...to assure
so far as possible every working man and woman in the Nation safe and healthful working
conditions and to preserve our human resources.”
Under the Act, the Occupational Safety and Health Administration (OSHA) was created
within the Department of Labor to:
• Encourage employers and employees to reduce workplace hazards and to imple-
ment new or improve existing safety and health programs;
• Provide for research in occupational safety and health to develop innovative ways
of dealing with occupational safety and health problems;
• Establish separate but dependent responsibilities and rights for employers and
employees for the achievement of better safety and health conditions;
• Maintain a reporting and recordkeeping system to monitor job-related injuries and
illnesses;
• Establish training programs to increase the number and competence of occupa-
tional safety and health personnel;
• Develop mandatory job safety and health standards and enforce them effectively;
and
• Provide for the development, analysis, evaluation, and approval of state occupa-
tional safety and health programs.
Since OSHA’s creation, the agency’s mission has been to save lives, prevent injuries, and
protect the health of America’s workers. To accomplish this, OSHA establishes and enforces
protective standards. Under these standards, employers must provide employees with jobs
and a place of employment free from recognized hazards that are causing, or are likely to
cause, death or serious physical harm.
In light of the many detailed and often complex regulatory requirements with which an
employer must comply, it is not surprising that questions arise and can lead to instances of
non-compliance. Unfortunately, non-compliance may mean employees are at risk. For this
reason, OSHA is authorized under the OSH Act to conduct inspections and take enforce-
ment actions.
OSHA considers inspection one of its primary tools for determining whether or not an
employer is in compliance with laws and regulations. As such, the agency inspects nearly
40,000 workplaces in the United States each year. This often results in citations and fines
of thousands of dollars against employers.
Introduction–1
While avoiding an OSHA inspection may not be possible, employers can avoid OSHA
citations. The best way to do this, in part, is ensuring that applicable regulatory requirements
are clearly understood. This is essential if employers are to effectively implement those
requirements.
How to Use This Manual
The regulations governing general industry employers are often very detailed and complex.
The purpose of this manual, therefore, is to provide detail and insight into those require-
ments and offer assistance for mastering compliance.
FAQs
The frequently asked questions (FAQs) format of this manual highlights specific questions
most often asked about OSHA general industry standards. The FAQs are divided into topics
that cover a variety of workplace safety issues, including powered industrial trucks, emer-
gency eyewashes and showers, exit routes, etc. This is intended to allow the user to quickly
locate information that may be relevant to their operations. These FAQs are not to be
considered complete and do not relieve employers from complying with all applicable fed-
eral, state, and local regulations.
Reference
Guidance such as Letters of Interpretation, OSHA contact information, a glossary, and an
index are provided for reference purposes. While this information does not mandate require-
ments, it nonetheless provides vital information should additional guidance be necessary.
This will help ensure continued compliance with regulatory requirements.
Still Have a Question?
While numerous compliance questions have been addressed in this manual, it is not pos-
sible to answer all questions an employer may have. However, because compliance is
paramount, employers are encouraged to contact the workplace safety experts at J. J.
Keller & Associates, Inc. for additional assistance. This may be done by logging in with a
username and password at the following website:
www.jjkellerpublications.com
Employers may ask any OSHA-related compliance question via the “Personal Assistant”
feature and receive an answer via email within one business day.
2–Introduction
A Word of Caution
While many requirements are provided in substantial detail, this manual is not intended to
take the place of the regulations found in the Code of Federal Regulations (CFR) at 29 CFR
1910, “Occupational Safety and Health Standards.” Due to the constantly changing nature
of these regulations, it is impossible to guarantee absolute accuracy of the material con-
tained herein. The Publisher and Editors, therefore, cannot assume any responsibility for
omissions, errors, misprinting, or ambiguity contained within this publication and shall not be
held liable in any degree for any loss or injury caused by such omission, error, misprinting,
or ambiguity presented in this publication.
This publication is designed to provide reasonably accurate and authoritative information in
regard to the subject matter covered. It is sold with the understanding that the Publisher is
not engaged in rendering legal, accounting, or other professional services. If legal advice or
other expert assistance is required, the services of a competent professional person should
be sought.
Introduction–3
Reserved
4–Introduction
Introduction
Are you totally in compliance with all regulations? Or have you implemented no safety or
health program whatsoever? Most companies fall somewhere between these two points.
Many companies are not even sure where they fall, as far as compliance is concerned.
Ensuring ongoing compliance is paramount to the safety and health of a workplace. How-
ever, there are hundreds of OSHA standards, directives, and guidance documents, etc.,
which employers must know and understand. As a result, implementation of required safety
requirements can be a time-consuming and confusing process.
Questions about specifics requirements often arise, and employers continually seek clari-
fication and additional guidance. The questions set forth in this manual are those most
frequently asked by employers. The answers to many of these questions are provided.
They are based on OSHA regulations, industry consensus standards, OSHA directives,
Letters of Interpretation, etc. This information is intended to enhance understanding of
OSHA regulations and compliance. These frequently asked questions are not to be con-
sidered complete and do not relieve employers from complying with all applicable federal,
state, and local regulations.
FAQS–1
Reserved
2–FAQS
A
Table of Contents
AEDs ................................................................................................... 1
Training........................................................................................... 1
Quantity .......................................................................................... 1
Aerial Lifts............................................................................................ 1
Definitions ....................................................................................... 1
Fall Protection .................................................................................. 1
Training........................................................................................... 2
Aisles and Walkways ............................................................................. 1
Markings and Labeling ....................................................................... 1
Spacing .......................................................................................... 1
3/13 A–1
Reserved
2–A 3/13
AEDs
Training
Must employees be trained to use automated external defibrillators (AEDs)?

Most states have a “Good Samaritan” statute which protects untrained responders who
provide help in an emergency. While they all differ slightly in the detail, basically what
is required is that if an individual expects no payment, and only does what a normal
person would do under the circumstances, they are protected. However, certain states
have rules about the use of AEDs, which in some cases require designated users to
have CPR/AED training. This training is typically part of a standard First Aid/CPR/AED
class, which is provided by the Red Cross, American Heart Association, National Safety
Council, or any number of local sources.
Quantity
Do I need an AED in the workplace?

OSHA does not require employers to have an AED on premises. As such, employers
should carefully evaluate whether or not one should be provided for use. Keep in mind
that at 1910.151(a) OSHA states, “The employer shall ensure the ready availability of
medical personnel for advice and consultation on matters of plant health.” In this case,
employers may wish to consult their medical professional on whether an AED is war-
ranted.
Also, some states require that certain facilities have AEDs; therefore, employers need
to check state statutes.
AEDs –1
Reserved
2–AEDs
Aerial Lifts
Definitions
What is an aerial lift?

OSHA defines an aerial lift as any vehicle-mounted work platform that can move ver-
tically and/or horizontally under 1910.67, and includes (but are not limited to):
• Aerial ladders,
• Extensible boom platforms,
• Articulating boom platforms,
• Vertical towers, or
• Combination of any of the above
Aerial lifts do not include any of the following:
• Manlifts,
• Forklifts,
• Scissor lifts, or
• Firefighting equipment.
Fall Protection
Is fall protection required when operating a man lift?

“Man lift” is a generic term used to reference various types of equipment used to lift a
man. Most often, this term refers to aerial lifts (e.g., bucket trucks). If utlizing an aerial
lift (as defined under 1910.67), OSHA views fall protection for these pieces of equip-
ment differently than for scissor lifts.
The fall protection requirements for aerial lifts are outlined in 1910.67(c)(2). OSHA says
that belting off to an adjacent pole, structure, or equipment when working from an aerial
lift is not allowed. Workers have to be tied-off to the boom or the basket. Also, workers
must always stand firmly on the floor of the basket, and can’t sit or climb on the edge
of the basket or use planks, ladders, or other devices for a work position.
The regulation also requires that a body belt be worn with a lanyard which has to be
short enough to prevent an employee from falling out, or being bounced out of, the
aerial lift.
3/13 Aerial Lifts–1

Training
Is separate training required for each type of aerial lift?

OSHA does not prescribe training requirements for aerial lifts used in general industry
under 1910.67; however, in a July 17, 1975 Letter of Interpretation (LOI) the agency
says:
“Employers have the responsibility of devising methods to train their operators in the
safe operation of aerial lifts. Only competent and careful operators should be assigned
these duties. The operator shall be trained in safe operations and made familiar with
the manufacturer’s manual, especially those parts which relate to operation, mainte-
nance, and safety of aerial devices.”
The American National Standards Institute (ANSI) also says employers must train both
operators and maintenance personnel in accordance with the equipment manufactur-
er’s recommendations, as well as those outlined in applicable ANSI standards. The
ANSI standards covering aerial lifts are:
• A92.2 – Vehicle-Mounted Elevating and Rotating Aerial Devices
• A92.5 – Boom-Supported Elevating Work Platforms
• A92.7 – Airline Ground Support Vehicle-Mounted Vertical Lift Devices
• A92.8 – Vehicle-Mounted Inspection and Maintenance Devices
• A92.9 – Mast-Climbing Work Platforms
It is advisable to follow the recommendations of the manufacturer, as well as those
prescribed in the applicable ANSI standard, to ensure that operation, maintenance, and
safety features specific to each aerial lift are clearly understood by operators as
instructed in the above LOI.
If used for construction work, employers must comply with 1926.453, “Aerial lifts,” and
1926.454, “Training requirements,” as referenced in a February 23, 2000 LOI.
2–Aerial Lifts 3/13

Aisles and Walkways
Markings and Labeling
What color must aisles and walkways be marked?

OSHA requires at 1910.22(b)(2) that aisles and walkways be appropriately marked, but
does not specify how that must be done. However, according to a May 15, 1972 Letter
of Interpretation (LOI) the agency says, “The lines used to delineate the aisles may be
any color so long as they clearly define the area considered as aisle space. The lines
may be composed of dots, square, strip or continuous, but they too must define the
aisle area. The recommended width of aisle markings varies from 2 inches to 6 inches;
therefore, any width 2 inches or more is considered acceptable.”
According to another LOI dated February 14, 1977, aisles and passageways must be
appropriately marked as required by the standard, but that “...does not require marking
by painted yellow lines only. Painted yellow lines are usually recognized as the most
convenient and inexpensive way to mark aisles and passageways since the lines
normally last several years without maintenance or repainting. Dirt floors or floors
having continuous concentrations of sand or dust would render the application of
painted floor markings infeasible and impractical, especially in foundries. Other appro-
priate methods such as marking pillars, powder stripping, flags, traffic cones, barrels
and many other devices are considered appropriate as long as recognition of such is
included in the vehicle operator and employee training programs. However, where the
need exists and there are no appropriate markings, citations will be issued.”
Spacing
How wide do aisles need to be?

The width of aisles and passageways is generally not specified in OSHA standards,
other than in specific instances. Examples of these specific instances include require-
ments for aisles 3 feet wide in inside storage rooms holding flammable and combustible
liquids (1910.106) and requirements for minimum exit access widths of 28 inches
(1910.36(g)(2)-(3)). And while 1910.22(b) and 1910.176(a) outlines general aisle
requirements, they do not specify aisle widths.
However, a May 15, 1972 OSHA Letter of Interpretation says, “The recommended
width of [permanent] aisles is at least 3 feet wider than the largest equipment to be
utilized, or a minimum of 4 feet.”
Aisles and Walkways–1

The width of the largest equipment includes the width of the widest carried if the load
is wider than the frame of the equipment. For example, forklifts might carry 12 foot long
lumber horizontally on the forks, so the aisle width must be 15 feet.
Employers must also comply with any applicable local or state building and fire codes.
Is there a minimum distance required to be maintained between equipment and

aisles?
OSHA requires at 1910.22(b) that “where mechanical handling equipment is used,
sufficient safe clearances shall be allowed for aisles, at loading docks, through door-
ways and where turns or passage must be made.” In addition, OSHA also says that
permanent aisles and passageways must be appropriately marked. They offer no
further guidance on the issue. As such, employers must evaluate their workplace to
determine an appropriate aisle width based on the specific conditions in the workplace.
2–Aisles and Walkways

B
Table of Contents
Bloodborne Pathogens .......................................................................... 1

Coverage ........................................................................................ 1
Exposure Control Plan ....................................................................... 3
Exposure Incidents............................................................................ 4
Hepatitis B Vaccination ...................................................................... 6
Laundry .......................................................................................... 8
Personal Protective Equipment .......................................................... 10
Recordkeeping................................................................................ 11
Regulated Waste............................................................................. 12
Sanitation ...................................................................................... 13
Sharps .......................................................................................... 14
Sharps Containers........................................................................... 14
Sharps Injury Log ............................................................................ 15
Spill Kit.......................................................................................... 16
Training ......................................................................................... 16
Universal Precautions ...................................................................... 17
B–1
Reserved
2–B

Coverage
Who is covered by the standard?

If an employer has even one employee who has occupational exposure to blood or
other potentially infectious materials (OPIM) the standard applies.
Occupational exposure is defined as reasonably anticipated skin, eye, mucous mem-
brane, or parenteral contact with blood or OPIM that may result from the performance
of an employee’s duties. Blood is defined as human blood, human blood components,
and products made from human blood. Other potentially infectious materials is defined
as the following:
• Saliva in dental procedures;
• Semen;
• Vaginal secretions;
• Cerebrospinal, synovial, pleural, pericardial, peritoneal, and amniotic fluids;
• Body fluids visibly contaminated with blood (along with all body fluids in situ-
ations where it is difficult or impossible to differentiate between body fluids);
• Unfixed human tissues or organs (other than intact skin);
• HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-
containing culture media or other solutions; and
• Blood, organs, or other tissues from experimental animals infected with HIV or
HBV.
Are employees who are designated to render first aid covered by the standard?
Yes. If employees are trained and designated as responsible for rendering first aid as
part of their job duties, they are covered by the protections of the standard. However,
OSHA will consider it a de minimis violation — a technical violation carrying no pen-
alties — if employees, who administer first aid as a collateral duty to their routine work
assignments, are not offered the pre-exposure hepatitis B vaccination, provided that a
number of conditions are met. In these circumstances, no citations will be issued.
This, however, does not apply to personnel who provide first aid at a first-aid station,
clinic, or dispensary, or to the healthcare, emergency response or public safety per-
sonnel expected to render first aid in the course of their work. The de minimis
Bloodborne Pathogens–1
classification is limited to persons who render first aid only as a collateral duty, respond-
ing solely to injuries resulting from workplace incidents, generally at the location where
the incident occurred. To merit the de minimis classification, the following conditions
also must be met:
• Reporting procedures must be in place under the exposure control plan to
ensure that all first-aid incidents involving the presence of blood or OPIM are
reported to the employer before the end of the work shift during which the
incident occurs.
• Reports of first-aid incidents must include the names of all first-aid providers
who rendered assistance and a description of the circumstances of the acci-
dent, including date and time, as well as a determination of whether an
exposure incident, as defined in the standard, has occurred.
• A report that lists all such first-aid incidents must be readily available to all
employees and provided to OSHA upon request.
• First-aid providers must receive training under the Bloodborne Pathogens
standard that covers the specifics of the reporting procedures. All first-aid
providers who render assistance in any situation involving the presence of
blood or other potentially infectious materials, regardless of whether or not a
specific exposure occurs, must have the vaccine made available to them as
soon as possible but in no event later than 24 hours after the exposure
incident. If an exposure incident as defined in the standard has taken place,
other post-exposure follow-up procedures must be initiated immediately, as
per the requirements of the standard.
Are employees such as housekeepers, maintenance workers, and janitors covered

by the standard?
Housekeeping workers in healthcare facilities may have occupational exposure, as
defined by the standard. Individuals who perform housekeeping duties, particularly in
patient care and laboratory areas, may perform tasks, such as cleaning blood spills and
handling regulated wastes, which cause occupational exposure.
While OSHA does not generally consider all maintenance personnel and janitorial staff
employed in non-healthcare facilities to have occupational exposure, it is the employ-
er’s responsibility to determine which job classifications or specific tasks and
procedures involve occupational exposure. For example, OSHA expects products such
as discarded sanitary napkins to be discarded into waste containers which are lined in
such a way as to prevent contact with the contents. At the same time, the employer
must determine if employees can come into contact with blood during the normal
handling of such products from initial pick-up through disposal in the outgoing trash.
If OSHA determines that sufficient evidence of reasonably anticipated exposure exists,
the employer will be held responsible for providing the protections of 1910.1030 to the
employees with occupational exposure.
2–Bloodborne Pathogens
Exposure Control Plan
What is an exposure control plan?

An exposure control plan is the employer’s written program that outlines the protective
measures an employer will take to eliminate or minimize employee exposure to blood
and other potentially infectious materials.
The exposure control plan must contain, at a minimum:
• The exposure determination which identifies job classifications with occupa-
tional exposure and tasks and procedures where there is occupational
exposure and that are performed by employees in job classifications in which
some employees have occupational exposure.
• The procedures for evaluating the circumstances surrounding exposure inci-
dents.
• A schedule of how other provisions of the standard are implemented, includ-
ing methods of compliance, HIV and HBV research laboratories and
production facilities requirements, hepatitis B vaccination and post-exposure
evaluation and follow-up, communication of hazards to employees, and
recordkeeping. Methods of compliance include Universal Precautions; engi-
neering and work practice controls (e.g., safer medical devices, sharps
disposal containers, hand hygiene); personal protective equipment; and
housekeeping, including decontamination procedures and removal of regu-
lated waste.
The plan must also include documentation of:
• The annual consideration and implementation of appropriate commercially
available and effective safer medical devices designed to eliminate or mini-
mize occupational exposure; and
• The solicitation of non-managerial healthcare workers (who are responsible
for direct patient care and are potentially exposed to injuries from contami-
nated sharps) in the identification, evaluation, and selection of effective
engineering and work practice controls.
In the exposure control plan, are employers required to list specific tasks that place
the employee at risk for all job classifications?
No. If all the employees within a specific job classification perform duties where occu-
pational exposure occurs, then a list of specific tasks and procedures is not required for
that job classification. However, the job classification (e.g., “nurse”) must be listed in the
plan’s exposure determination, and all employees within the job classification must be
included under the requirements of the standard.
Can tasks and procedures be grouped for certain job classifications in the plan?
Yes. Tasks and procedures that are closely related may be grouped. In other words,
they must share a common activity, such as “vascular access procedure” or “handling
of contaminated sharps.”
Does the exposure control plan need to be a separate document?

No. The exposure control plan may be part of another document, such as the facility’s
health and safety manual, as long as all components are included. However, in order
for the plan to be accessible to employees, it must be a cohesive entity by itself or there
must be a guiding document which states the overall policy and goals and references
the elements of existing separate policies that comprise the plan. For small facilities,
the plan’s schedule and method of implementation of the standard may be an anno-
tated copy of the final standard that states on the document how the provisions of the
standard are implemented. Larger facilities could develop a broad facility program,
incorporating provisions from the standard that apply to their establishments.
How often must the exposure control plan be reviewed?

The standard requires an annual review of the exposure control plan. In addition,
whenever changes in tasks, procedures, or employee positions affect, or create new
occupational exposure, the existing plan must be reviewed and updated accordingly.
Must the exposure control plan be accessible to employees?

Yes. The exposure control plan must be accessible to employees. The location of the
plan may be adapted to the circumstances of a particular workplace, provided that
employees can access a copy at the workplace during their workshift. If the plan is
maintained solely on a computer, employees must be trained to operate the computer.
A hard copy of the exposure control plan must be provided within 15 working days of
the employee’s request as specified under 1910.1020.
Exposure Incidents
What should be included in the evaluation of an exposure incident?

Following an exposure incident, employers are required to document, at a minimum,
the route(s) of exposure and the circumstances under which the exposure incident
occurred. To be useful, the documentation must contain sufficient detail about the
incident. There should be information about the following:
• The engineering controls in use at the time and work practices followed;
• Description of the device in use;
• The protective equipment or clothing used at the time of the exposure inci-
dent;
• Location of the incident and procedures being performed when the incident
occurred;
• Employee’s training; and
• The source individual (unless the employer can establish that identification is
infeasible or prohibited by state or local law).
The employer should then evaluate the policies and “failures of controls” at the time of
the exposure incident to determine actions that could prevent future incidents.
What information must the employer provide to the healthcare professional following
an exposure incident?
The healthcare professional must be provided with a copy of the standard as well as the
following information:
• A description of the employee’s duties as they relate to the exposure incident;
• Documentation of the route(s) and circumstances of the exposure;
• The results of the source individual’s blood testing, if available; and
• All medical records relevant to the appropriate treatment of the employee,
including vaccination status, which are the employer’s responsibility to main-
tain.
What testing must be done on the source individual?

The employer must identify and document the source individual, if known, unless the
employer can establish that identification is not feasible or is prohibited by state or local
law. The source individual’s blood must be tested as soon as feasible, after consent is
obtained, in order to determine HIV and HBV infectivity. The information on the source
individual’s HIV and HBV testing must be provided to the evaluating healthcare pro-
fessional.
If consent cannot be obtained and is required by state law, the employer must docu-
ment in writing that consent cannot be obtained.
Also, the results of the testing must be provided to the exposed employee. The
exposed employee must be informed of applicable laws and regulations concerning
disclosure of the identity and infectious status of the source individual.
When is the exposed employee’s blood tested?

After consent is obtained, the exposed employee’s blood is collected and tested as
soon as feasible for HIV and HBV serological status. If the employee consents to the
follow-up evaluation after an exposure incident, but does not give consent for HIV
serological testing, the blood sample must be preserved for 90 days. If, within 90 days
of the exposure incident, the employee elects to have the baseline sample tested for
HIV, testing must be done as soon as feasible.
What information does the healthcare professional provide to the employer following
an exposure incident?
The employer must obtain and provide to the employee a copy of the evaluating
healthcare professional’s written opinion within 15 days of completion of the evaluation.
The healthcare professional’s written opinion for hepatitis B is limited to whether hepa-
titis B vaccination is indicated and if the employee received the vaccination. The written
opinion for post-exposure evaluation must include information that the employee has
been informed of the results of the evaluation and told about any medical conditions
resulting from exposure that may require further evaluation and treatment. All other
findings or diagnoses must be kept confidential and not included in the written report.
What type of information must be provided to the employee(s) following an exposure

incident?
The standard requires that post-exposure counseling be given to employees following
an exposure incident. Counseling concerning infection status, including results and
interpretation of all tests, will assist the employee in understanding the potential risk of
infection and in making decisions regarding the protection of personal contacts. For
example, counseling should include U.S. Public Health Service (USPHS) recommen-
dations about the transmission and prevention of HIV. Counseling based on the
USPHS recommendations must also be provided for HBV and HCV and other
bloodborne pathogens, as appropriate. In addition, counseling must be made available
regardless of the employee’s decision to accept serological testing.
Hepatitis B Vaccination
Who must be offered the hepatitis B vaccination?

The hepatitis B vaccination series must be made available to all employees who have
occupational exposure. However, the employer does not have to make the hepatitis B
vaccination available to employees who have previously received the vaccination
series, who are already immune as their antibody tests reveal, or for whom receiving
the vaccine is prohibited for medical reasons.
When must the hepatitis B vaccination be offered to employees?

The hepatitis B vaccination must be made available within 10 working days of initial
assignment, after appropriate training has been completed. Thus, arranging for the
administration of the first dose of the series must be done at a time which will enable
this schedule to be met. Only persons who render first aid only as a collateral duty,
responding solely to injuries resulting from workplace incidents, generally at the loca-
tion where the incident occurred would not have to be offered the pre-exposure
hepatitis B vaccination (OSHA would consider this a de minimus violation — a technical
violation carrying no penalties).
Can pre-screening be required for hepatitis B titer? Post-screening?

The employer cannot require an employee to take a pre-screening or post-vaccination
serological test. An employer may, however, decide to make pre-screening available at
no cost to the employee. All medical evaluations and procedures, including the hepatitis
B vaccine and vaccination series, are to be provided according to the current recom-
mendations of the U.S. Public Health Service.
According to the current guidelines, employees who have ongoing contact with patients
or blood and are at ongoing risk for percutaneous injuries should be tested for anti-HBs
one to two months after the completion of the three-dose vaccination series. Non-
responders must receive a second three-dose series and be retested after the second
series. Non-responders must be medically evaluated.
Can the employer make up its own declination form?

If an employee declines the hepatitis B vaccination, the employer must ensure that the
employee signs a hepatitis B vaccine declination. The declination’s wording is found in
Appendix A of the standard. A photocopy of the Appendix may be used as a declination
form, or the words can be typed or written onto a separate document.
An employer may use different words if they convey the same information. However,
any additions to that language should be made for the sole purpose of improving
employee comprehension. Forms must not add language that would discourage
employee acceptance of the vaccine, add liability concerns, or require the employee to
provide confidential medical information.
Can employees refuse the hepatitis B vaccination?

Employees have the right to refuse the hepatitis B vaccine and/or any post-exposure
evaluation and follow-up. However, the employer must properly inform the employee of
the benefits of the vaccination and post-exposure evaluation through training. The
employee also has the right to decide to take the vaccination at a later date if he or she
so chooses. The employer must make the vaccination available at that time.
Is a routine booster dose of hepatitis B vaccine required?

The U.S. Public Health Service does not recommend routine booster doses of hepatitis
B vaccine, so they are not required at this time.
Whose responsibility is it to pay for the hepatitis B vaccine?

The responsibility lies with the employer to make the hepatitis B vaccine and vaccina-
tion, including post-exposure evaluation and follow-up, available at no cost to the
employee.
Laundry
What does OSHA mean by the term “contaminated laundry?”

Contaminated laundry means laundry (e.g., towels, bedsheets, clothing) which has
been soiled with blood or other potentially infectious materials or may contain sharps.
How should contaminated laundry be handled?

Contaminated laundry must be handled as little as possible with a minimum of agita-
tion. It must be bagged or containerized at the location where it was used and cannot
be sorted or rinsed in the location of use. Also, contaminated laundry must be placed
and transported in bags or containers labeled or color-coded in accordance with
1910.1030(g)(1)(i).
When a facility utilizes Universal Precautions in the handling of all soiled laundry,
alternative labeling or color-coding is sufficient if it permits all employees to recognize
the containers as requiring compliance with Universal Precautions.
Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-
through or leakage from the bag or container, the laundry must be placed and
transported in bags or containers which prevent soak-through and/or leakage of fluids
to the exterior.
Also, the employer must ensure that employees who have contact with contaminated
laundry wear protective gloves and other appropriate personal protective equipment.
Are employees allowed to take their protective equipment home and launder it?
Employees are not permitted to take their protective equipment home and launder it. It
is the responsibility of the employer to provide, launder, clean, repair, replace, and
dispose of personal protective equipment.
Do employers have to buy a washer and dryer to clean employees’ personal protec-
tive equipment?
There is no OSHA requirement stipulating that employers must purchase a washer and
dryer to launder protective clothing. It is an option that employers may consider.
Another option is to contract out the laundering of protective clothing. Employers may
also choose to use disposable personal protective clothing and equipment.
What water temperature and detergent types are acceptable when laundering per-
sonal protective equipment?
The decontamination and laundering of protective clothing are governed by the laundry
provisions of 1910.1030(d)(4)(iv). Washing and drying the garments should be done
according to the clothing manufacturer’s instructions.
When are labels required?

A warning label that includes the universal biohazard symbol as specified at
1910.1030(g)(1)(i)(B) followed by the term “biohazard” must be included on:
• Bags/containers of contaminated laundry;
• Bags/containers of regulated waste;
• Refrigerators and freezers that are used to store blood or OPIM; and
• Bags/containers used to store, dispose of, transport, or ship blood or other
potentially infectious materials (e.g., specimen containers).
In addition, contaminated equipment which is to be serviced or shipped must have a
readily observable label attached which contains the biohazard symbol and the word
“biohazard” along with a statement relating which portions of the equipment are con-
taminated.
What are the required colors for the biohazard label?

The label must be fluorescent orange or orange-red or predominantly so, with symbols
and lettering in a contrasting color. The label must be either an integral part of the
container or affixed as close as feasible to the container by a string, wire, adhesive, or
other method to prevent its loss or unintentional removal.
Can there be substitutes for the biohazard label?

Yes. Red bags or red containers may be substituted for the biohazard label.
What are the exceptions to the labeling requirement?

Labeling is not required for:
• Containers of blood, blood components, and blood products bearing an FDA-
required label that have been released for transfusion or other clinical uses;
• Individual containers of blood or other potentially infectious materials that are

placed in secondary labeled containers during storage, transport, shipment,
or disposal;
• Specimen containers, if the facility uses Universal Precautions when handling
all specimens, the containers are recognizable as containing specimens, and
the containers remain within the facility;
• Laundry bags or containers containing contaminated laundry may be marked
with an alternative label or color-coded provided the facility uses Universal
Precautions for handling all soiled laundry, and the alternative marking per-
mits all employees to recognize the containers as requiring compliance with
Universal Precautions. If contaminated laundry is sent off-site for cleaning to
a facility which does not use Universal Precautions in the handling of all soiled
laundry, it must be placed in a bag or container which is red in color or labeled
with the biohazard label described above; and
• Regulated waste that has been decontaminated.
Personal Protective Equipment
What type of personal protective equipment (PPE) must be worn to reduce or elimi-
nate exposure to bloodborne pathogens?
The standard requires that PPE be “appropriate.” PPE will be considered “appropriate”
only if it does not permit blood or other potentially infectious materials (OPIM) to pass
through to, or reach, the skin, employees’ underlying garments, eyes, mouth, or other
mucous membranes under normal conditions of use and for the duration of time that
the PPE will be used. This allows the employer to select PPE based on the type of
exposure and the quantity of blood or OPIM which can be reasonably anticipated to be
encountered during performance of a task or procedure.
Who is responsible for providing personal protective equipment (PPE)?

The responsibility for providing, laundering, cleaning, repairing, replacing, and dispos-
ing of PPE at no cost to employees rests with the employer. Employers are not
obligated under the standard to provide general work clothes to employees, but they
are responsible for providing PPE. For example, if laboratory jackets or uniforms are
intended to protect the employee’s body or clothing from contamination, they are to be
provided at no cost by the employer.
Does protective clothing need to be removed before leaving the work area?
Yes. OSHA requires that personal protective equipment be removed before leaving the
work area. While “work area” must be determined on a case-by-case basis, a work area
is generally considered to be an area where work involving occupational exposure
occurs or where the contamination of surfaces may occur.
What type of eye protection is required when working with blood or other potentially
infectious materials (OPIM)?
The use of eye protection would be based on the reasonable anticipation of facial
exposure. Masks in combination with eye protection devices, such as glasses with solid
side shields, goggles, or chin-length face shields, shall be worn whenever splashes,
spray, spatter, or droplets of blood or OPIM may be generated and eye, nose, or mouth
contamination can be reasonably anticipated.
When should gloves be changed?

Disposable gloves shall be replaced as soon as practical after they have become
contaminated, or as soon as feasible if they are torn, punctured, or their ability to
function as a barrier is compromised. Hands must be washed after the removal of
gloves used as personal protective equipment, whether or not the gloves are visibly
contaminated.
Recordkeeping
What must be contained in an employee medical record?

The medical record includes:
• The name and social security number of the employee;
• A copy of the employee’s hepatitis B vaccination status including the dates of
all the hepatitis B vaccinations and any medical records relative to the employ-
ee’s ability to receive the vaccination;
• Copies of all results of examinations, medical testing, and follow-up proce-
dures;
• Copies of the healthcare professional’s written opinion; and
• Copies of the information provided to the healthcare professional.
Who keeps the medical records?

The employer is responsible for the establishment and maintenance of medical
records. However, these records may be kept off-site at the location of the healthcare
provider. The employer must ensure that the medical records are kept confidential and
are not reported or disclosed without the express written consent of the worker, except
as required by the standard or as may be required by law.
How long must medical records be kept?

Medical records must be kept for the duration of employment plus 30 years.
What must be included in a bloodborne pathogen training record?

Bloodborne pathogen training records must contain the:
• Dates of the training,
• Contents or a summary of the training sessions,
• Names and job titles of all persons attending the training, and
• Names and qualifications of the persons conducting the training.
How long must bloodborne pathogen training records be kept?

Training records must be retained for three years from the training date.
Regulated Waste
What does OSHA mean by the term “regulated waste?”

The Bloodborne Pathogens standard uses the term “regulated waste” to refer to the
following categories of waste which require special handling:
1. Liquid or semi-liquid blood or other potentially infectious materials (OPIM),
2. Items contaminated with blood or OPIM and which would release these sub-
stances in a liquid or semi-liquid state if compressed,
3. Items that are caked with dried blood or OPIM and are capable of releasing
these materials during handling,
4. Contaminated sharps, and
5. Pathological and microbiological wastes containing blood or OPIM.
Are feminine hygiene products considered regulated waste?

OSHA does not generally consider discarded feminine hygiene products to fall within
the definition of regulated waste. The intended function of products such as sanitary
napkins is to absorb and contain blood. The absorbent material of which they are
composed would, under most circumstances, prevent the release of liquid or semi-
liquid blood or the flaking off of dried blood.
OSHA expects these products to be discarded into waste containers which are properly
lined with plastic or wax paper bags. Such bags should protect employees from physi-
cal contact with the contents.
At the same time, it is the employer’s responsibility to determine the existence of
regulated waste. This determination is not based on actual volume of blood, but rather
on the potential to release blood (e.g., when compacted in a waste container). If OSHA
determines that sufficient evidence of regulated waste exists, either through observa-
tion (e.g., a pool of liquid in the bottom of a container, dried blood flaking off during
handling), or based on employee interviews, citations may be issued if the employer
does not comply with the provisions of the standard on regulated waste.
How must regulated waste be disposed?

Regulated waste must be placed in containers which are:
• Closable;
• Constructed to contain all contents and prevent leakage of fluids during han-
dling, storage, transport or shipping;
• Labeled or color-coded in accordance with 1910.1030(g)(1)(i); and
• Closed before removal to prevent spillage or protrusion of contents during
handling, storage, transport, or shipping.
If outside contamination of the regulated waste container occurs, it must be placed in
a second container. The second container must be:
• Closable;
• Constructed to contain all contents and prevent leakage of fluids during han-
dling, storage, transport, or shipping;
• Labeled or color-coded in accordance with 1910.1030(g)(1)(i); and
• Closed before removal to prevent spillage or protrusion of contents during
handling, storage, transport, or shipping.
Disposal of all regulated waste must be in accordance with applicable regulations.
Sanitation
What type of disinfectant can be used to decontaminate equipment or working sur-

faces which have come in contact with blood or other potentially infectious materials
(OPIM)?
OSHA’s position is that EPA-registered tuberculocidal disinfectants, diluted bleach
solutions, and EPA-registered disinfectants that are labeled as effective against both
HIV and HBV as well as sterilants/high-level disinfectants cleared by the FDA, meet the
requirement in the standard and are “appropriate” disinfectants to clean contaminated
surfaces, provided that such surfaces do not become contaminated with agent(s) or
volumes of or concentrations of agent(s) for which higher level disinfection is recom-
mended. The particular disinfectant used, as well as the frequency with which it is used,
will depend upon the circumstances in which a given housekeeping task occurs (i.e.,
location within the facility, type of surface to be cleaned, type of soil present, and tasks
and procedures being performed). The employer’s written schedule for cleaning and
decontamination should identify such specifics on a task-by-task basis.
What alternatives are acceptable if soap and running water are not available for
handwashing?
Antiseptic hand cleansers in conjunction with clean cloth/paper towels or antiseptic
towelettes are examples of acceptable alternatives to running water. However, when
these types of alternatives are used, employees must wash their hands with soap and
running water as soon as feasible. These alternatives are only acceptable at worksites
where it is infeasible to provide soap and running water.
Sharps
Must used razor blades be disposed of in a sharps container?

Uncontaminated used box cutter blades, uncontaminated knives, uncontaminated
razor blades, uncontaminated broken glass, other uncontaminated sharps, or any other
uncontaminated object that can penetrate the skin do not fall under the definition of
regulated waste nor contaminated sharps. Handling uncontaminated sharps would not
pose an “occupational exposure” as defined in 1910.1030(b). If no occupational expo-
sure exists, then 1910.1030 does not need to be met. OSHA does not have any
disposal requirements for uncontaminated sharps.
Sharps Containers
What type of container should be purchased to dispose of sharps?

Sharps containers are made from a variety of materials from cardboard to plastic. As
long as they meet the definition of a sharps container (i.e., containers must be closable,
puncture-resistant, leakproof on sides and bottom, and labeled or color-coded), OSHA
would consider them to be acceptable.
How should sharps containers be handled?

Sharps containers must be maintained upright throughout use, replaced routinely, and
not be allowed to overfill.
When removing sharps containers from the area of use, the containers shall be:
• Closed immediately before removal or replacement to prevent spillage or
protrusion of contents during handling, storage, transport, or shipping.
• Placed in a secondary container if leakage is possible, which must be:

❍ Closable;
❍ Constructed to contain all contents and prevent leakage during han-
dling, storage, transport, or shipping; and
❍ Labeled or color-coded according to paragraph (g)(1)(i) of the stan-
dard.
• Reusable containers shall not be opened, emptied, or cleaned manually or in
any other manner which would expose employees to the risk of percutaneous
injury.
Upon closure, duct tape may be used to secure the lid of a sharps container as long as
the tape does not serve as the lid itself.
Where should sharps containers be located?

Sharps containers must be easily accessible to employees and located as close as
feasible to the immediate area where sharps are used or can be reasonably anticipated
to be found (e.g., laundries, restrooms). In areas where there may be difficulty placing
sharps containers in the immediate use area, alternatives include using containers that
are lockable or are designed to prevent removal of syringes while maintaining easy
accessibility for discarding. If a mobile cart is used in these areas, an alternative would
be to lock the sharps container onto the cart.
Sharps Injury Log
What recordkeeping does OSHA require for exposure incidents?

Any employer who is required to maintain a log of occupational injuries and illnesses
under OSHAs Recordkeeping standard (29 CFR Part 1904) is also required to estab-
lish and maintain a sharps injury log for the recording of percutaneous injuries from
contaminated sharps.
Employers must also record all work-related needlestick injuries and cuts from sharp
objects that are contaminated with another person’s blood or other potentially infectious
materials on the OSHA 300 Log. Employers may use the OSHA 300 Log to meet the
requirements of the sharps injury log provided they enter the same information required
for the sharps injury log on the OSHA 300 Log and maintain the records in a way that
segregates sharps injuries from other types of work-related injuries and illnesses, or
allows sharps injuries to be easily separated.
Employers must enter sharps injury cases on the OSHA 300 Log and the sharps injury
log without entering the employee’s name. If an employee is splashed or exposed to
blood or OPIM without being cut or punctured, the incident must be recorded on the
OSHA 300 Log if it results in the diagnosis of a bloodborne illness or if it meets one or
more of the recording criteria in 1904.7. If an employer is exempted from the OSHA
recordkeeping rule, the employer does not have to maintain a sharps log.
Spill Kit
What must be in a bloodborne pathogen spill kit?

A bloodborne pathogen “spill kit” or “clean-up kit” is not required. However, a kit con-
taining certain items may help the employer ensure workers have the proper items
necessary for safe and effective cleanup of incidents involving blood or other potentially
infectious materials. These items could include (but are not limited to):
• Personal protective equipment (e.g., gloves);
• Appropriate disinfectants (EPA registered tuberculocide or sterilant) or bleach;
• Housekeeping supplies (e.g., absorbent towels, kitty litter); and
• Proper waste containers and labels for regulated waste.
Training
Which employees must be trained?

All employees with occupational exposure must receive initial and annual training. In
addition, training must be provided when changes (e.g., modified/new tasks or proce-
dures) affect a worker’s occupational exposure. Part-time and temporary employees
are covered and are also to be trained on company time.
What are the qualifications that a person must possess in order to conduct
bloodborne pathogen training?
The person conducting the training is required to be knowledgeable in the subject
matter covered by the elements in the training program and be familiar with how the
course topics apply to the workplace that the training will address. The trainer must
demonstrate expertise in the area of occupational hazards of bloodborne pathogens.
Examples of individuals who could conduct training include health care professionals
such as control practitioners, nurse practitioners, and registered nurses. Non-
healthcare professionals who could conduct training include industrial hygienists,
epidemiologists, or professional trainers provided that they can demonstrate evidence
of specialized training in the area of bloodborne pathogens.
Universal Precautions
What is meant by the term “Universal Precautions?”

Universal Precautions are OSHA’s required method of control to protect employees
from exposure to all human blood and other potentially infectious materials. The term
“Universal Precautions” refers to a concept of bloodborne disease control which
requires that all human blood and certain human body fluids be treated as if known to
be infectious for HIV, HBV, or other bloodborne pathogens.
Reserved
C
Table of Contents
Compressed Gases ............................................................................... 1

Definitions ....................................................................................... 1
Inspection........................................................................................ 1
Propane .......................................................................................... 3
Storage ........................................................................................... 3
Use ................................................................................................ 5
Confined Spaces ................................................................................... 1
Air Monitoring................................................................................... 1
Alternate Entry ................................................................................. 1
Entry .............................................................................................. 2
Identification .................................................................................... 2
Reclassification ................................................................................ 4
Recordkeeping ................................................................................. 5
Rescue ........................................................................................... 6
Training........................................................................................... 7
Written Program ............................................................................... 8
9/14 C–1
Reserved
2–C 9/14
Compressed Gases
Definitions
What is a compressed gas?

Compressed gas is defined as:
• A material or mixture in a container with an absolute pressure of 40 psi at 70
degrees Fahrenheit.
• A material or mixture in a container with an absolute pressure exceeding 104
psi at 130 degrees Fahrenheit.
• A liquid material having a vapor pressure exceeding 40 psi absolute at 100
degrees Fahrenheit.
What does “connected for use” mean?

OSHA says at 1910.253(b)(3) that “connected for use” (i.e., “in actual use” or “attached
ready for use”) means that the regulator on the compressed gas cylinder is installed.
When work is complete and it is reasonably anticipated that gas will not be drawn from
the cylinder within the next 24 hours, the employer must comply with the storage
requirements for compressed gases. However, if it is reasonably anticipated that the
cylinder will be used within the next 24 hours, the storage requirements need not be
met.
Inspection
Do compressed gas cylinders need to be inspected?

Employers must visually inspect compressed gas cylinders to determine that they are
in safe condition under 1910.101. Visual inspections must be conducted as prescribed
in the Hazardous Materials Regulations of the Department of Transportation (49 CFR
Parts 171–179 and 14 CFR Part 103). Where those regulations are not applicable,
visual inspections must be conducted in accordance with Compressed Gas Associa-
tion, Inc. (CGA) Pamphlet C-6-1968, “Standards for Visual Inspection of Compressed
Gas Cylinders.”
3/13 Compressed Gases–1

CGA Pamphlet C-6 provides detailed instructions, and Appendix A provides a sample
inspection report form. In general, all part of a cylinder (e.g., valves, neck rings, hoses,
manifold, regulator, etc.) should be inspected, at a minimum, for:
• Corrosion or pitting;
• Cracks;
• Denting;
• Bulging;
• Gouges;
• Leaks;
• Arbitrary paint; and
• Oil, grease, and other foreign material.
Leaking regulators, cylinder valves, or other equipment must be taken out of service.
How do compressed gases need to be marked?

Ensure that cylinders, containers, pipes, etc. are clearly marked so that the gas can be
easily identified. Labels should not be defaced or removed. Do not accept or use
containers whose content labels are not legible. Segregate these items and return them
to the supplier. Do not use the container color to identify the cylinder content; do not
repaint the container.
In addition, all gas lines leading from a compressed gas supply should be clearly
labeled or identified (some states require specific labeling of cylinders, containers, and
pipes).
Do compressed air pipes need to be marked or color-coded?

OSHA does not specifically require compressed air pipes to be labeled. However,
employers should check with state and local authorities to see if there are any state
regulations which would apply. If no requirements apply, employers may wish to use the
standard color scheme recommended by the American National Standards Institute
standard A13.1-2007, “Scheme for the Identification of Piping Systems,” which calls for
white letters on a blue background.
2–Compressed Gases 3/13

Propane
Can propane tanks be stored inside a building?

In addition to CGA Pamphlet P-1 requirements, OSHA says at 1910.110(f)(4)(i), “
Storage within buildings not frequented by the public (such as industrial buildings),” that
the quantity of LP-Gas stored cannot exceed 300 pounds (approximately 2,550 cubic
feet in vapor form) except as provided in subparagraph (5), which requires the con-
struction and use of special buildings or rooms for larger quantities. This requirement
limits the inside storage of propane tanks to a maximum of about four average-sized
forklift fuel cylinders. Do not count those connected for use.
How far away from a building must an outside propane tank be located?
OSHA says that outside storage of up to 500 lbs. requires no separation from buildings.
Quantities of 501 to 2,500 lbs. requires no separation from buildings except for those
on an adjoining property, next to any sidewalk, or near busy thoroughfares. In these
instances, separation must be at least 10 feet. Quantities over 2,501 lbs. must be
separated as follows:
• 2,501 to 6,000 lbs. – 10 feet.
• 6,001 to 10,000 lbs. – 20 feet.
• Over 10,000 lbs. – 25 feet.
Also, at 1910.110(f)(2)(i) OSHA states “Containers in storage shall be located so as to
minimize exposure to excessive temperature rise, physical damage, or tampering by
unauthorized persons.”
Local or state fire code may also address this issue; therefore, local authorities should
be consulted.
Storage
How must compressed gases be separated during storage?

Employers should always refer to the manufacturer’s storage requirements and Safety
Data Sheet; however, compressed gases should be grouped and stored based on their
hazard class. For example, separation must be maintained between fuel and oxidizing
gases and oxygen, but inert gases may be stored next to either. Provide adequate
space or segregate by partitions and post a conspicuous sign that identifies the gas or
hazard class. Storage areas should be dry, well-drained, ventilated, and fire-resistant.

How must compressed gas cylinders be stored?

OSHA addresses compressed gases in general at 1910.101; however, the standard
does not provide detail with regard to storage of cylinders. Instead, 1910.101(b), refers
employers to CGA Pamphlet P-1-1965 for in-plant handling of all compressed gases in
cylinders.
With regard to cylinders, CGA P-1 says (among other things) that:
• Storage areas must be designed to accommodate the various gases with
adequate spacing or segregation by partitioning so that containers can be
grouped by hazard.
• Storage areas must be dry, well-drained, ventilated, and fire-resistant.
• Consideration should be given to separate storage of full and empty contain-
ers.
• Temperatures in the storage area must not exceed 125°F.
• There must be adequate separation from combustibles as specified by fed-
eral, state, and local regulations.
• There must always be a valve protection cap (if provided) in place.
• Containers may not be exposed to corrosive chemicals or fumes or stored
near readily ignitable substances.
• Containers must be protected from cuts, punctures, or other abrasions of the
metal.
• Containers must be secured with brackets, chains, or straps to prevent falling
or damage.
• Containers must not be stored near walkways, elevators, stairs, unprotected
platform edges, or where heavy objects may strike or fall on them.
• The method of storage must not expose the cylinders to tampering by unau-
thorized persons.
May cylinders by permanently stored on a transport dolly?

For general industry, OSHA says that as long as the cylinders are “connected for use,”
(i.e., the cylinders have the regulators and hose attached) then they may stay on the
dolly.
This storage practice may not be used in construction, however. If gas is not to be
drawn for 24 hours, the welding/cutting outfit must be broken down and the cylinders
put into storage. OSHA says that this is due to the rougher nature of most construction
sites.

Can cylinders be stored on their sides?

According to CGA Pamphlet P-1-1965, which OSHA has incorporated by reference at
1910.101(b), only properly secured gas cylinders with a water volume of less than 305
cubic inches may be stored in a horizontal position.
Do empty gas cylinders have to be chained or secured like full ones?

According to 1910.101(b) the in-plant handling, storage, and utilization of all com-
pressed gases in cylinders must be in accordance with CGA Pamphlet P-1-1965, which
is incorporated by reference. CGA P-1 says that empty and full containers should be
segregated. Also, all cylinders must be stored with the safety cap in place, secured or
nested, protected from any damage, or exposure to salt, corrosive chemical, or fumes.
Can cylinders be stored on concrete?

Cylinders must be stored in a way that prevents bottom corrosion/rusting. Therefore,
prolonged exposure to a damp environment should be avoided. Storage on well-
drained, paved surfaces (e.g., concrete and asphalt) should protect cylinders as
necessary.
Do compressed gas storage areas need signage?

OSHA and the Department of Transportation (DOT) require that storage sites and
areas for certain compressed gases be marked with placards indicating the presence
of the gas, associated hazards, safety measures, and other warnings.
Additional labeling and marking requirements for certain compressed gases (e.g.,
hydrogen) are outlined in the applicable OSHA or DOT gas standards.
Use
What is the procedure for safely transferring compresses gases?

Transfer of compressed gases from one container to another should be performed only
by the gas supplier or by personnel familiar with the hazards. They must be trained and
qualified to use the proper transfer equipment, and should have detailed written oper-
ating procedures that include equipment inspections and maintenance procedures.
How must compressed gas cylinders be moved?

OSHA requires that a “special truck” be used to transport compressed gas cylinders
that are “connected for use” (i.e. the regulators are installed). In a September 9, 1993
Letter of Interpretation, OSHA states that a “special truck” is a vehicle or cart which

provides for stable support of cylinders during movement. The “special truck” must be
designed so that the following conditions are met:
• Cylinders must be held in an erect or nearly erect position, and
• Protection of the cylinder valves and regulators must be provided.
Compressed gas cylinders which are not secured to a “special truck” must have their
regulators removed and valve-protection caps installed.
Also, CGA Pamphlet P-1, which has been adopted by reference, states (Section 3.5,
“Safe Handling of Cylinders”) that “A suitable hand truck, forklift truck, or similar mate-
rial handling device should be used with the container properly secured to the device.”
Both OSHA and CGA discuss securing cylinders during transport, but neither specifi-
cally requires a chain. A chain would be effective at securing cylinders, as would any
comparable method that would secure the cylinder to the truck.
What safety measures must be used when using compressed gas cylinders?
When using any compressed gas (i.e., cylinders, portable tanks, rail tankcars, or motor
vehicle cargo tanks), employers must comply with the provisions outlined in CGA
Pamphlet P-1-1965, which is incorporated by reference in the OSHA standard.
In specific regard to the use of compressed gas cylinders:
• Cylinder valves must be closed when work is finished.
• Cylinder valves must be closed before moving cylinders.
• Cylinders must never be used as rollers or supports, whether full or empty.
• Don’t place cylinders where they become part of an electric circuit or use them
as a ground during welding.
• Don’t subject cylinders to temperature extremes.
• Unless connected to a manifold, oxygen from a cylinder must not be used
without first attaching an oxygen regulator to the cylinder valve.
• Before connecting a regulator to the cylinder valve, the valve must be opened
slightly for an instant and then closed.
• Avoid dragging or sliding cylinders.
• Don’t lift cylinders by the caps.
• Move cylinders with a suitable hand truck, lift truck, or crane with a cradle or
platform.
• Never drop cylinders or strike them against one another or other surfaces.

Confined Spaces
Air Monitoring
Is air monitoring required if the space does not contain hazardous chemicals?
The standard says that “when testing for atmospheric hazards, test first for oxygen,
then for combustible gases and vapors, and then for toxic gases and vapors.” However,
OSHA guidance has said “the type of testing that needs to be performed...is dependant
on the hazards that are present within the space; employers are not required to test
substances which will not potentially be present.” And the standard itself says “Test or
monitor the permit space as necessary to determine if acceptable entry conditions are
being maintained during...entry operations.” [bold emphasis added] If the employer is
certain there is no atmospheric hazard, testing is not required.
How often should air monitoring equipment be calibrated?

The standard does not say, but OSHA would expect an employer to follow the equip-
ment manufacturer’s instructions for the instrument’s calibration, use, and
maintenance. Employer may also want to consult with an industrial hygienist for rec-
ommendations on air monitoring equipment selection and use. The standard has an
Appendix on atmospheric testing that says the equipment has to be sensitive and
specific enough to identify and evaluate the atmoshperic hazards.
Alternate Entry
When may alternate entry procedures be used?

The alternate entry procedures at 1910.146(c)(5) can be used when the only hazard in
a permit space is an atmospheric hazard that can be controlled through continuous
forced air ventilation. If the employer follows the alternate entry procedures, they do not
need to comply with paragraphs (d) through (f) and (h) through (k). If the space has
other hazards, such as an internal configuration that could trap an entrant or mechani-
cal equipment that needs to be locked out, then the alternate entry procedures would
not apply.
9/14 Confined Spaces–1

Entry
Must the entry supervisor be there during the whole entry?

Yes, but the entry supervisor can also be an entrant or an attendant. So the entrant can
also be the entry supervisor. If one person is doing both jobs, he or she has to have the
training for both jobs. And, OSHA allows the responsibility for entry supervisor to
transfer to another person during the entry.
Identification
What is a confined space?

OSHA defines a confined space as meeting the following criteria:
1. Is large enough for an employee to bodily enter and work;
2. Has limited or restricted means of entry and exit; and
3. Is not designed for continuous occupancy.
If the space does meet the definition of “confined space,” then the employer needs to
further evaluate the space to determine whether it meets the definition of “permit-
required confined space.”
When is a permit required for a confined space?

A permit-required confined space is a confined space (as defined) that has one or
more of the following characteristics:
1. Contains or has a potential to contain a hazardous atmosphere; or
2. Contains a material that has the potential for engulfing an entrant; or
3. Has an internal configuration that could trap or asphyxiate an entrant by
inwardly converging walls or a floor which slopes downward and tapers to a
small cross section; or
4. Contains any other recognized serious safety or health hazard.
If a space meets the definition of permit-required confined space, then the require-
ments of 1910.146 apply.
2–Confined Spaces 9/14

Is a permit required to reach into a space with a tool?

If it is a permit space, OSHA considers entry to take place as soon as any part of the
body breaks the plane of the opening into the space. This even includes hands and
arms to reach into a permit space to use a tool or do air monitoring tests. If, for example,
the space has a flammable atmosphere and using the tool causes a spark that ignites
combustible dusts or flammable gases, the person at the entry could easily be injured
in a fire or explosion. In other situations, the person could touch exposed energized
parts near the opening or come into contact with hazardous chemicals. Of course if the
person puts his or her head into the permit space, a hazardous atmosphere can cause
asphyxiation very quickly.
An October 18, 1995 OSHA Letter of Interpretation (LOI) says that a partial entry
without a permit, such as reaching into a permit space, would be a de minimis violation
if the entrant isn’t exposed to any possibility for injury or illness. For example, a de
minimis citation would be issued if the worker reached into a space that is only a permit
space because it has exposed live electrical parts or unguarded rotating parts that are
10 feet away from the opening. The entrant could not contact anything hazardous by
reaching in with just his arm.
If the person is reaching into a space that is too small to bodily enter, then the space
does not meet the definition of “confined space,” so the standard on permit spaces
does not apply. But, an employer still must provide appropriate protections for whatever
hazards are in the space.
If the opening to the space is too small for someone to enter do we need a permit to
look inside or reach into the space?
In this situation, OSHA’s guidance has said the standard does not apply. The space
does not meet the definition of confined space because the person can’t “bodily enter.”
However, the space can still have atmospheric, electrical, or other hazards that need
to be addressed.
When must a sign be applied to entry points of permit-required confined spaces?

Once an employer has determined a permit-required confined space exists, the
employer is obligated by 1910.146(c)(2) to inform exposed employees either by posting
a sign or other effective means. Since the purpose of (c)(2) is to provide the exposed
employees with information to protect them from the hazard, the “when” an employee
must be informed is before the next entry.

Do non-permit required confined spaces require a sign to be posted at the entrance?

OSHA does not specifically require employers to post signs at the entrance of a non-
permit required confined space. Generally speaking, a permit-required confined space
is a confined space with an actual or potential “serious safety and health hazard.” If a
confined space is not a permit space, then that confined space has been determined
to have no “serious” hazards. Therefore, there would be little need to identify the space.
However, there could be less than serious hazards in an ordinary nonpermit required
confined space. Posting a sign on a non-permit space would simply be going beyond
requirements.
What are the requirements for a confined space warning sign?

Warning signs must be large enough to be noticed by someone who is curious about
the space.
The standard does suggest the wording on the sign read: DANGER — Permit-Required
Confined Space. Do Not Enter.
OSHA also says an employer does not have to use signs if other methods are used,
such as additional training, if they are truly effective in warning all the employees who
could reasonably be expected to enter the space and is at least effective as a sign.
An employer could also lock the entrance or have a cover that can only be opened with
special tools instead of using signs, if all employees know that they are not to be
opened without authorization. And, if they are left unlocked or open for some reason,
temporary warning signs would be required.
Even if signs are used, employers might have to train employees who have trouble
reading or speaking English so the meaning of the signs are clearly understood.
Reclassification
When can a permit-required confined space be reclassified?

In accordance with 1910.146(c)(7), the space may be reclassified as a non-permit
confined space if the space poses no actual or potential atmospheric hazards and if all
hazards within the space are eliminated without entry into the space.
OSHA discusses reclassification in a November 15, 1993 Letter of Interpretation (LOI)
in which the agency discusses a metal curing oven by saying:
“An employer who eliminates the hazards from a permit space, as provided by para-
graph (c)(7) of the standard, can reclassify that space as a non-permit confined space.
That reclassification, which would remain in effect as long as the hazards remain
eliminated, would allow employers to have employees enter the curing ovens without
implementing a permit space program.

“Item 1 of your letter addresses using Lockout-Tagout (1910.147) procedures to elimi-

nate the hazards of moving machinery and natural gas. We agree that through the
application of 1910.147, the hazards of stored energy and moving machinery would be
eliminated. We do not agree that lockout-tagout would eliminate the natural gas hazard.
Hazard elimination in that case would require one of the techniques (blanking, blinding,
misaligning or removing sections of lines or pipe, and double block and bleed system)
referenced in the definition of “isolation” (see paragraph (b) of 1910.146).
“Item 2 indicates that a cool down time is allotted so that the latent heat of the oven
does not create a heat exposure hazard. We concur with the cool down practice to
eliminate this heat stress potential. However, we suggest the actual job safety practice
indicate a maximum oven temperature allowable or other measurable parameter
(period of time) allotted before entry.
“Item 3 describes your process for verifying that there are no atmospheric hazards. The
standard does not specify a duration of time over which verification monitoring must be
done. However, we do not see a problem with the documented baseline monitoring
program being conducted over an 8 hour period of time as long as the employer can
prove that atmospheric hazards have been eliminated from the ovens before an
employee enters. Verification monitoring with the ventilation system off will be needed
to establish that atmospheric hazards have been eliminated. OSHA agrees that spot air
monitoring for atmospheric monitoring for atmospheric hazards is not necessarily
required by paragraph (c)(7), however, it is the most appropriate way of determining
that atmospheric hazards have not manifested themselves.
“Item 4 prohibiting solvents or welding during non-permit entries is a sound practice and
should be continued.”
Another LOI dated December 02, 2005 includes the following:
“If the source has been truly removed, i.e. no piping, containers, residual, etc., and the
flammable material is not brought into the space by any mechanism, then there would
not be a potential atmospheric hazard for that material.”
If the hazards are eliminated for the length of the entry through lockout and blanking,
etc., the space may be reclassified as a non-permit according to the criteria in
1910.146(c)(7).
Recordkeeping
Do entry logs have to be kept? If so, for how long?

OSHA does not require employers to keep a written log of all permit space entries.
OSHA does require cancelled entry permits be kept for one year. They are used to
review the program and make any necessary revisions. If a log of entries is kept, it
would be up to company policy regarding how long to maintain older entries.

If an evaluation concludes a company does not have any confined spaces, is docu-
mentation required that indicated the assessment was done?
OSHA does not require an employer to document that the facility has been evaluated
for the presence of permit spaces. If they are present at an employer’s facility, post
signs and warn employees. If an employer has confined spaces that are not permit
spaces, they need to be reevaluated if there are changes in how they are used or
configured. These changes could make a non-permit space become a permit space.
Rescue
May an employer use an external emergency service to provide confined space

rescue?
The employer has to evaluate a rescue service’s ability to respond in a timely manner
and their proficiency with the rescue-related tasks and equipment they’ll use in the
permit spaces.
From the services evaluated, employers must select one that has the capability to
reach the victims in the amount of time appropriate for the hazards during the entry.
Select a service that has the equipment they’ll need and the skill to use it. If specialized
equipment is necessary, the employer might have to provide it – but who provides what
rescue equipment should be spelled out in the agreement with the service selected.
The employer also has to inform the rescue service of the hazards they may confront
when they do a rescue, and provide the rescue service with access to permit spaces
so that they can develop rescue plans and practice rescues. The employer also needs
to be sure that the members of the service are trained in first aid and CPR.
The employer must also do these same things when setting up an in-house rescue
team. But with an in-house team, the employer is responsible for providing all the
equipment and PPE (and training the workers on how to use it). Training would have
to include information on how to be an entrant and how to do the rescues. The rescue
team employees would need training in basic first aid and CPR (at least one team
member on active rescue duty must hold current certification in first aid and CPR). In
addition, employees on a rescue team must practice making rescues at least once
every 12 months.
Can an employer have a general rescue plan and customize it when having an actual
entry and add additional conditions or rescue equipment to be used?
OSHA does not provide details on how to develop rescue plans. The standard does
require necessary rescue equipment to be listed on the permit before an entry starts.
It’s up to the employer to decide how they will develop their rescue plans, but need to
be detailed enough so that rescues will be efficient and effective.

What is the best method for retrieval from a horizontal space, and is it required to
monitor the entrants breathing zone (or as close as possible) as done in a vertical
confined space entry?
Rescues for horizontal entries are essentially the same as for vertical entries. The
entrant must wear a harness attached to a retrieval line (or wristlets if a harness is
infeasible). The retrieval line may be attached to a manually operated winch to facilitate
the non-entry rescue or, in the case of a horizontal entry, the rescue team may be able
to pull on the rope to remove the entrant — practice drills will let demonstrate whether
or not this is feasible.
And, with any entry, the harness and retrieval line are not necessary if their use would
not help the rescue. If the entrant could get stuck on obstructions while being removed
or if the retrieval line could get tangled up with an airline hose or anything else, then it
would be infeasible to use the harness and line. In this case, the rescue team must
enter the space to rescue the entrant in case of an emergency.
Training
Who may conduct employee training?

The trainer has to sign or initial the training certification, but OSHA doesn’t set any other
requirements for the trainer. OSHA generally expects trainers to have the knowledge
and skills necessary to conduct effective training. And, it’s still up to the employer to
ensure employees are being adequately trained to meet the standard’s requirements.
Do entrants need annual training?

No. There is no requirement for annual or other regularly-scheduled training. Employ-
ees need to have their initial training when they are first assigned to permit-space entry
duties. After that, they need training under certain conditions:
• Before their assigned duties are changed,
• When there is a change in entry operations that presents new hazards, and
• Whenever the employer determines that they are not correctly following the
procedures.
Must attendants have CPR training?

Members of the rescue team have to be trained in first aid and cardiopulmonary CPR.
The attendant can be a member of the rescue team. One of the duties of the attendant
is to perform non-entry rescues as specified in the employer’s rescue procedures. If the
attendant has non-entry or any other rescue duties, then CPR training is needed. In the
standard’s requirements for rescue teams, it says that the employer has to make sure

that at least one member of the rescue team who has a current certification in first aid
and CPR is available on the team.
When and how must employers inform employees about the presence of permit–
required confined spaces?
OSHA clarified the standard in July 22, 1998 Letter of Interpretation in which the agency
says “Once an employer has determined a permit–required confined space exists (a
confined space with an actual or potential hazard), the employer is obligated by para-
graph 1910.146(c)(2) to inform exposed employees either by posting a sign or other
effective means. Since the purpose of this paragraph is to provide the exposed employ-
ees with information to protect them from the hazard, the ‘when’ an employee must be
informed is before the next entry.”
In the compliance directive on permit–required confined spaces (CPL 2.100) OSHA
states, “Ordinarily, information about permit spaces is most effectively and economi-
cally communicated through the use of signs. Consequently, signs would be the
principal method of warning under the standard. Alternative methods, such as addi-
tional training, may be used where they are truly effective in warning all employees who
could reasonably be expected to enter the space. It is the employer’s obligation to
assure that an alternative method is at least as effective as a sign. In some cases,
employers may have to provide training in addition to signs, to protect employees who
do not speak English or who would have difficulty understanding or interpreting signs.”
OSHA’s directive considers locked entry ports and states, “If a space has a locked entry
cover or panel, or an access door that can only be opened with special tools, the use
of signs may be unnecessary if the employer ensures that all affected employees are
informed about such spaces and know that they are not to be opened without taking
proper precautions, including temporary signs, to restrict unexpected or unknowing
entry.”
Written Program
Is a written program required for workplaces that have permit-required confined

spaces, but never enter them ?
Although not required to prepare a full written permit-required confined spaces pro-
gram, an employer will want to document that the workplace has been assessed, that
permit spaces have been identified, and outline the steps taken to deal with these
spaces. This includes methods to train/inform employees about the hazards of the
spaces and why they should not attempt to enter them. In the event of an OSHA
inspection, the compliance officer will want to know how permit spaces are dealt with.
Providing written documentation is one of the best methods to satisfy OSHA’s request.

If an employer chooses not to allow employees to enter confined spaces, how would
this affect their written program and training requirements?
If employees will not enter permit spaces, the employer must first take effective mea-
sures to prevent employees from entering the permit spaces. One way to do this is to
lock the entrance or otherwise make it unlikely that someone could enter it. In addition,
the employer must meet the standard’s requirements for:
• Evaluating the workplace to identify permit spaces,
• Posting signs or otherwise informing employees of the danger of the permit
spaces,
• Reevaluating spaces as needed after changes in configurations or use, and
• Sharing information with contract employers who may enter the permit
spaces.
An employer would not have any other written program or training requirements.

Reserved

Reserved
D–1
Reserved
2–D
E
Table of Contents
Electric Power Generation, Transmission, and Distribution ....................... 1

Applicability ..................................................................................... 1
Contractors ...................................................................................... 1
Fall Protection .................................................................................. 2
First Aid .......................................................................................... 2
Operation and Maintenance ................................................................ 3
Personal Protective Equipment ............................................................ 4
Training........................................................................................... 5
Emergency Action Plans ........................................................................ 1
Applicability ..................................................................................... 1
Emergency Action Plan ...................................................................... 1
Emergency Contacts ......................................................................... 3
Evacuation ...................................................................................... 3
Fire Prevention Plan .......................................................................... 4
Notification ...................................................................................... 4
Training........................................................................................... 5
Emergency Eyewashes and Showers ...................................................... 1
Access............................................................................................ 1
Applicability ..................................................................................... 1
Battery Charging............................................................................... 3
Capacity.......................................................................................... 3
Enforcement .................................................................................... 3
Flushing Fluid .................................................................................. 4
Inspection........................................................................................ 5
Installation ....................................................................................... 5
Location .......................................................................................... 6
Maintenance .................................................................................... 7
Operation ........................................................................................ 7
Types ............................................................................................. 8
Ergonomics .......................................................................................... 1
Lifting ............................................................................................. 1
Musculoskeletal Disorders (MSDs) ....................................................... 2
9/14 E–1

Work Stations................................................................................... 5
Exit Routes........................................................................................... 1
Access............................................................................................ 1
Design ............................................................................................ 1
Doors ............................................................................................. 2
Lighting ........................................................................................... 3
Obstructions .................................................................................... 4
Signs .............................................................................................. 4
Extension Cords ................................................................................... 1
Assembly ........................................................................................ 1
Inspection........................................................................................ 1
Power Strips .................................................................................... 2
Repair ............................................................................................ 2
Temporary Wiring.............................................................................. 3
Use ................................................................................................ 3
Eye and Face Protection ........................................................................ 1
Contact Lenses ................................................................................ 1
Eyeglasses ...................................................................................... 1
Maintenance and Care....................................................................... 2
Selection ......................................................................................... 2
Training........................................................................................... 4
Use ................................................................................................ 4
Welding........................................................................................... 4
2–E 9/14
Electric Power Generation, Transmission, and

Distribution
Applicability
Does the standard impact customers that are end-users of electricity, but do not
generate, transmit, or distribute it?
The scope of the standard covers the operation and maintenance of electric power
generation, control, transformation, transmission, and distribution lines and equipment.
If an employer is not engaged in any of these activities, the requirements would not
apply. An employer is also exempt if they have supplementary electric generating
equipment that is used to supply a workplace for emergency or standby purposes only.
Also, the standard does not apply if an employer has an emergency generator. An
emergency generator, as would all of a facilities electrical equipment, falls under 1910
Subpart S, “Electrical.”
Contractors
If we are the considered the contract employer, do our employees have to follow the
host employers work rules?
The standard does not require that specifically; however, a contractor does have to
coordinate their work rules and procedures with the host employer’s work rules and
procedures. This way both groups of workers are protected.
What is the definition of a host employer?

A host employer is an employer that operates, or that controls, the operating proce-
dures for an electric power generation, transmission, or distribution installation on
which a contract employer is performing work covered by the standard. The host
employer does not have to be the entity that hired the contract employer.
9/14 Electric Power Generation, Transmission, and Distribution–1

Fall Protection
Do qualified workers that are climbing or moving around on poles need to use fall
protection?
Yes. These employees need to use fall protection, unless the employer can demon-
strate that is infeasible or would create a greater hazard that not using it. OSHA
considered “climbing” to include going up and down the pole.
What are the requirements for bucket truck fall protection?

The standard requires that employees working from an aerial lift be protected by either
a fall restraint system or a personal fall arrest system. A body belt connected to a
lanyard cannot be used. A lanyard connected to a harness as part of a personal fall
arrest system can be used, however.
First Aid
How is first aid supposed to be addressed?

OSHA references first aid by directing employers to the requirements under 1926.951.
However, employers must provide more than first aid. OSHA says, “when employees
are performing work on exposed lines or equipment at 50 volts or more, for field work
involving two or more employees at a work location, at least two trained persons must
be available.”
This means that employees must be trained in cardiopulmonary resuscitation (CPR).
This is the same CPR training requirement for general industry employers as outlined
under 1910.269(b)(1).
For fixed work locations like a substation, OSHA says the number of trained persons
must be sufficient to ensure that each employee exposed to electric shock can be
reached within 4 minutes by a trained person. However, where the existing number of
employees is insufficient to meet this requirement (at a remote substation, for
example), each employee at the work location has to be a trained employee.
2–Electric Power Generation, Transmission, and Distribution 9/14

Operation and Maintenance
How does an employer establish “minimum approach distances”?

OSHA covers this in Appendix B to Subpart V of Part 1926 called, “Working on Exposed
Energized Parts.” The tables in this Appendix can be used to establish the minimum
approach distances for the conditions covered by the tables. There are quite a few of
these tables in Appendix B, so careful review of each is necessary.
Is 50 volts considered the minimum danger level for electric shock?

OSHA considers 50 volts to be the recognized threshold for hazardous electric shock.
Several OSHA and national consensus standards recognize this 50-volt threshold.
OSHA’s general industry and construction electrical standards both require guarding of
live parts energized at 50 or more volts. Also, the NFPA 70E and the National Electrical
Safety Code have electrical safety requirements starting at 50 volts.
What is the definition of enclosed spaces?

Section 1926.953 contains requirements for entry into and work in enclosed spaces.
These include manholes, vaults, tunnels, or shafts that have a limited means of egress
or entry, is not designed for employee entry under normal operating conditions, and
under these normal operating conditions, does not have a hazardous atmosphere.
However, it can contain a hazardous atmosphere under abnormal conditions.
Usually in this case, the hazardous atmosphere is caused by lack of adequate venti-
lation in the space. This can normally be controlled through the use of continuous
forced air ventilation. These types of practices are widely recognized and are currently
used in electric, telecommunications, and other underground utility industries.
When are two employees required to work together?

The two-person rule is addressed at 1926.960. Except as provided in paragraph
(b)(3)(ii), at least two employees must be present while any employee performs the
following types of work:
• Installation, removal, or repair of lines energized at more than 600 volts,
• Installation, removal, or repair of de-energized lines if an employee is exposed
to contact with other parts energized at more than 600 volts,
• Installation, removal, or repair of equipment, such as transformers, capaci-
tors, and regulators, if an employee is exposed to contact with parts energized
at more than 600 volts,

• Work involving the use of mechanical equipment, other than insulated aerial
lifts, near parts energized at more than 600 volts, and
• Other work that exposes an employee to electrical hazards greater than, or
equal to, the electrical hazards posed by operations listed specifically in para-
graphs (b)(3)(i)(A) through (b)(3)(i)(D).
The reason for the two-person rule is that the second person can begin to administer
CPR within four minutes after an employee loses consciousness due to an electric
shock.
How must employers select the proper protective clothing and equipment?
Appendix E to Subpart V provides guidance relating to:
• How to select clothing that does not ignite,
• How to select protective clothing with an acceptable arc rating, and
• When the standard requires arc-rated head and face protection.
Do employers have to pay for the flame-resistant and arc-rated clothing and other
arc-flash protective equipment required by the standard?
Yes. As required by OSHA’s general rules on employer payment for personal protective
equipment under 1910.132(h) and 1926.95(d)), employers must pay for the flame-
resistant and arc-rated clothing and other arc-flash protective equipment required by
the electric power generation, transmission, and distribution standard.
Can employees wear 100-cotton clothing instead of flame-resistant clothing?

OSHA says that because 100-percent cotton clothing could pose an ignition hazard,
using this instead of flame-resistant clothing is not allowed. However, it is common
practice to allow workers to wear 100-percent cotton clothing under the outer layer of
flame-resistant clothing. Cotton can not be used as the outer protective layer, but it can
be worn in a clothing system. All-in-all, OSHA does not consider cotton clothing to be
protective.
Must employees wear arc-rated footwear?

OSHA says that it found no evidence in the record of an employee sustaining burn
injuries to the feet in an arc-related incident. As such, arc-rated boots are not required.
Heavy-duty work shoes or boots is sufficient.

How must fire-resistant clothing be maintained and cleaned?

OSHA says that professional laundering is needed. Since the employer must provide
fire-resistant clothing at no charge to the worker, the employer is also responsible for
making sure the clothing is still able to protect the worker. Therefore, the employer must
set up some procedure or system to ensure that fire-resistant clothing is effective either
by employing third-party laundering or having the employee wash and maintain the
clothing.
Training
Is it a requirement that an employee’s job briefing be a face-to-face exchange of

information?
OSHA does not require a specific face-to-face exchange of information between the
employer and worker. That is because there are lots of ways assignments are made,
including through radio communication with the employee in charge, via a written work
order, by electronic communication via computer, etc. It can also be provided through
training, in a written safety manual, or by written work procedures. The key here is that
the exchange of info has to communicate the necessary information about a particular
job in question.

Reserved

Applicability
Who must develop an emergency action plan?

OSHA’s Emergency Action Plan (EAP) standard at 1910.38 applies to those companies
which are required to have an EAP by one of these standards:
• 1910.66(e)(9), Powered Platforms for Building Maintenance
• 1910.119(n), Process Safety Management of Highly Hazardous Chemicals
• 1910.120 Hazardous Waste Operations and Emergency Response
(HAZWOPER)
• 1910.157 (a)-(b), Portable Fire Extinguishers
• 1910.160(c), Fixed Extinguishing Systems
• 1910.164(e)(3), Fire Detection Systems
• 1910.272(d), (h)(2), Grain Handling Facilities
• 1910.1017(I), Vinyl Chloride
• 1910.1027(h), Cadmium
• 1910.1044(I), 1,2-dibromo-3-chloropropane (DBCP)
• 1910.1045(I), Acrylonitrile
• 1910.1047(h), Ethylene Oxide (EtO)
• 1910.1050(d), Methylenedianiline (MDA)
• 1910.1450 (Appendix A), Occupational Exposure to Hazardous Chemicals in
Laboratories
OSHA requires at 1910.157 that employers either train all employees to use fire extin-
guishers or implement an EAP. For all practical purposes, all employers must develop
a plan to ensure the safety of their employees should an emergency occur.
Emergency Action Plan
Must an EAP be written?

Yes, an emergency action plan must be in writing, kept in the workplace, and available
to employees for review in accordance with 1910.28(b).
3/13 Emergency Action Plans–1

What must be covered in an EAP?

At a minimum, the emergency action plan must include:
• Procedures for reporting fires and other emergencies;
• Procedures for emergency evacuation policy and procedure, including the
type of evacuation (i.e., fire, tornado, etc.);
• Procedures to account for all employees after evacuation;
• Procedures to be followed by employees performing rescue or medical duties;
• Emergency escape procedures and route assignments (e.g., floor plans,
workplace maps, and safe or refuge areas);
• Procedures for employees who remain to perform or shut down critical plant
operations, operate fire extinguishers, or perform other essential services that
cannot be shut down for every emergency alarm before evacuating; and
• Names, titles, departments, and telephone numbers of individuals both within
and outside your company to contact for additional information or explanation
of duties and responsibilities under the emergency plan.
What should an evacuation policy and procedure include?

When establishing an evacuation policy and procedure, consider:
• Conditions under which an evacuation would be necessary,
• Specific evacuation procedures, including routes and exits,
• A clear chain of command and designation of the person authorized to order
an evacuation or shutdown,
• Procedures for assisting people with disabilities or who do not speak English,
and
• What employees will continue to run or if critical operations will be shut down
during an evacuation.
Is an EAP required for each company location?

The emergency action plan must be tailored to the workplace; therefore, each company
location should have a plan.
Keep a copy of the EAP in a convenient location so that employees can access it, or
provide all employees a copy.
In the event of an emergency, access to employees home telephone numbers, medical
information, etc. may be important. Keep a copy of this information in a secure location
outside of the main facility.
2–Emergency Action Plans 3/13

Emergency Contacts
Are emergency telephone numbers required to be posted?

According to 1910.165(b)(4), general industry employers must post emergency tele-
phone numbers near telephones, or employee notice boards, and other conspicuous
locations when telephones serve as a means of reporting emergencies. If an employer
is required to complete an EAP under 1910.38 (or 1926.35), then that plan must include
procedures for reporting a fire or another emergency. It is the employer’s decision
whether or not those procedures require employees to refer to emergency telephone
numbers posted near telephones.
Also, state and local fire codes may be more stringent and call for the posting of
emergency telephone numbers.
Evacuation
What is the role of an evacuation warden?

A responsible person may be chosen to lead and coordinate the emergency plan.
Employees must know who this coordinator is and understand that the coordinator has
the authority to make decisions during emergencies. The coordinator should be
responsible for:
• Determining when an emergency exists and activating emergency proce-
dures;
• Supervising all efforts, including evacuating personnel;
• Coordinating outside emergency services, and ensuring that they are notified
when necessary; and
• Directing the shutdown of plant operations when required.
How must employees be accounted for after an evacuation?

Accounting for all employees following an evacuation is critical. Confusion in the
assembly areas can lead to delays in rescuing anyone trapped in the building, or
unnecessary and dangerous search-and -rescue operations.

To ensure the fastest, most accurate accountability of employees, consider including

these steps in the EAP:
• Designate assembly areas where employees should gather after evacuating;
• Develop procedures for taking a head count after the evacuation. Identify the
names and last known location of anyone not accounted for and pass this
information to the coordinator;
• Establish a method for accounting for non-employees such as suppliers and
customers; and
• Establish procedures for further evacuation in case the incident expands,
such as sending employees home or providing transportation to an offsite
location.
Fire Prevention Plan
Is an EAP necessary if the company already has a fire prevention plan?

The employer must implement a fire prevention plan and an EAP that meets all the
requirements of 1910.38, “Emergency Action Plans.”
The exceptions to fire extinguisher distribution in 1910.157(b)(2), “Portable Fire Extin-
guishers,” apply where the employers’ written plan allows only designated employees
to use fire extinguishers, while all other employees evacuate the area upon sounding
of the alarm.
Notification
How must employees be alerted in an emergency?

All employees, including disabled workers, must be alerted to evacuate or take other
action in the event of an emergency. As such, the EAP should include:
• A description of the alarms used to alert employees to evacuate or perform
other actions identified in the plan;
• An explanation of the emergency communications system which will be used
to notify employees and contact local emergency responders; and
• What means will be used to ensure that alarms are heard, seen, or otherwise
perceived by everyone in the workplace, such as an auxiliary power supply in
the event of power failure.

How can an alarm system be effective in noisy work areas, or in areas where hearing
impaired employees are working?
Alarm devices are commonly equipped with both visual and audible alarms. A strobe
light can be activated in conjunction with the audible alarm. Employers should contact
an alarm service provider for more information on the type of alarms available, and for
guidance on the optimal placement of alarms in their facility.
Training
How must employees be trained?

Employers must review the EAP with employees when:
• The plan is first developed,
• Employees are initially hired,
• Employees responsibilities under the plan change, and
• The plan is changed.
General training for employees should include:
• Individual roles and responsibilities;
• Threats, hazards, and corrective actions;
• Notification, warning, and communications procedures;
• Means for locating family members in an emergency;
• Emergency response procedures;
• Evacuation, shelter, and accountability procedures;
• Location and use of common emergency equipment; and
• Emergency shutdown procedures.
While annual training is not required, consider a yearly refresher. Offer training after:
• Introducing new equipment, materials, or processes into the workplace that
affect evacuation routes;
• Changing the layout or design of the facility; and
• Revising or updating emergency procedures.
If there are 10 or fewer employees, the EAP may be communicated orally.
Once everyone has been trained, it is a best practice to hold practice drills occasionally.

Reserved

Access
What is considered an obstructed path of travel to an eyewash or shower station?

If an employee is hindered in some way from either getting to or using an eyewash or
shower station, it would be considered obstructed access under American National
Standards Institute (ANSI) Z358.1-2009, “Emergency Eyewash and Shower Equip-
ment,” standard. Specifically, the ANSI standard states that “a door is considered to be
an obstruction.” Other obstructions would include stairs, machinery (e.g., a conveyor
that must be lifted), stored materials, etc. Also, the standard says that stations should
not be located near potential hazards that may be adjacent to the path of travel that
might cause further injury.
How much space must be left clear around eyewashes and showers?
The OSHA standard only says that emergency eyewashes/showers, “be provided
within the work area for immediate emergency use.” And the ANSI standard says that
the path of travel to an emergency eyewash and shower must be “free of obstructions
that may inhibit its immediate use.” Obviously, if any items or equipment are placed
around a unit, it would likely impede immediate use.
Applicability
When is an eyewash and/or shower required?

The OSHA eyewash/shower requirement at 1910.151(c) states, “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.” [bold emphasis added]
OSHA further addresses this issue in Letter of Interpretation (LOI) dated April 14, 2008
which says, “.....the employer must determine if employees can or will be exposed
during the course of their duties to hazardous materials in such a way that the protec-
tions of an eyewash or emergency shower would be necessary. If hazardous materials
are present at a worksite in such a way that exposure could not occur (for example,
in sealed containers that will not be opened, or caustic materials in building piping),
then an eyewash or emergency shower would not be necessary. However, if the build-
ing piping containing caustic materials has, at certain locations, a spigot or tap from
9/14 Emergency Eyewashes and Showers–1

which the contents are to be sampled or withdrawn and employees are expected to
perform such tasks, then, certainly, an eyewash and/or emergency shower would be
needed where this task is to occur.”
Ask:
1. Are injurious corrosive materials present onsite? (Refer to the SDS for guid-
ance)
2. Are employees exposed?
If the answer to both of these questions is ‘yes,’ then an emergency eyewash and/or
shower is required. If the answer is ‘no’ to either of those questions, then a unit would
not need to be provided.
Ultimately, OSHA expects the employer to determine the level of potential risk to
employees and provide protection accordingly.
When is an emergency shower required as opposed to just an eyewash?

Whether an emergency shower is needed in addition to an eyewash is dependent upon
several factors, including what the Safety Data Sheet (SDS) says about eye vs. bodily
injury. The need for one or the other is sometimes specified. Also, what is the possibility
that the chemical could splash or spill onto the employee’s body vs. just the eyes. How
much chemical are employees being exposed to, etc.? These are all questions employ-
ers need to ask during a hazard assessment. Based on the answers, the employer then
must decide what the level of exposure and risk is and provide the necessary protection
accordingly.
Should an eyewash be made available to remove metal fragments, wood chips, etc.?
OSHA says that eyewashes (and showers) are intended to be used for strong acids and
alkilis. That doesn’t mean, however, that they wouldn’t be useful under other circum-
stances. In these cases, employers should consult with a medical professional
regarding the best course of treatment when workers are exposed to potential eye
hazards.
Is an eyewash or shower required for small amounts of corrosive chemicals?

The OSHA standard requires that an emergency eyewash or shower be provided if
teyes or body is exposed to any amount of injurious corrosive material.
2–Emergency Eyewashes and Showers 9/14

Battery Charging
Is an eyewash or shower required in a battery charging area?

OSHA specifically addresses battery charging areas in a number of Letters of Inter-
pretation, including a July 26, 1994 letter which states, “At locations where hazardous
chemicals are handled by employees (e.g. battery servicing facility), proper eyewash
and body drenching equipment must be available.” In other words, if maintenance is
being done, suitable facilities for quick drenching or flushing of the eyes and body are
required. On the other hand, no eyewash or shower is required if maintenance is not
performed on powered industrial truck batteries; that is, when batteries are charged
only.
It would still be considered a “best practice” to have an eyewash or shower station in
the charging area, and your liability insurance carrier may require you have one there.
Capacity
Does it matter whether a 16 gallon flow station vs. a plumbed eyewash unit is used?
Are both in compliance?
OSHA permits the use of a self-contained eyewash unit IF that unit can supply 15
minutes of flushing fluid, but it also must provide the required flow rate of .4 gallons per
minute. A 16 gallon self-contained unit would likely be able to provide 15 minutes of
flushing at the required flow rate, but must be verified through testing. It would be
compliant provided all other eyewash requirements were met.
Enforcement
Is ANSI Z358.1 enforced by OSHA?

Yes, OSHA does use ANSI Z358.1-2009 in enforcement. Under 1910.151(c), OSHA
requires that “suitable” facilities for the quick drenching of the eyes and body be pro-
vided where employees may be exposed to injurious corrosive materials. The agency
says in a November 1, 2002 LOI that, “If OSHA inspects a workplace and finds unsuit-
able facilities for quick drenching or flushing of the eyes and body, a citation under 29
CFR 1910.151(c) would be issued. When determining whether the eyewash or shower
facilities are suitable given the circumstances of a particular worksite, OSHA may
refer to the most recent consensus standard regarding eyewash or shower

equipment… .” Without the ANSI standard, employers would find it difficult to demon-
strate to OSHA exactly how their eyewash and/or shower units were “suitable”
exclusive to the regulatory language under 1910.151(c) since it is limited and vague.
Flushing Fluid
What type of water must be used for eyewashes and showers?

While OSHA does not address this issue, ANSI standard Z358.1-2009 for emergency
eyewash and shower equipment defines acceptable flushing fluid as one of the follow-
ing:
• Potable water,
• Preserved water,
• Preserved buffered saline solution, or
• Other medically acceptable solution manufactured and labeled in accordance
with applicable government regulations.
Any of these are acceptable, but a fluid that is appropriate for the type of decontami-
nation treatment must be chosen.
What does “potable” mean?

Potable means “safe to drink.” If water used for eyewash and showers is from a
municipality, then it meets the definition of flushing fluid per the ANSI standard because
it’s treated and tested to meet Environmental Protection Agency (EPA) drinking water
standards. If, however, well water is used it’s suitability must be confirmed via adequate
testing to ensure it meets the same EPA requirements and can thus be used for
emergency eyewashes and showers.
What temperature must flushing fluid be?

OSHA does not specify a water temperature for eyewashes or showers under
1910.151(c), but addresses the issue in an April 18, 2002 Letter of Interpretation by
saying, “it is the employer’s responsibility to assess the particular conditions related to
the eyewash/shower unit, such as water temperature, to ensure that the eyewash/
shower unit provides suitable protection against caustic chemicals/materials to which
employees may be exposed.”
OSHA also says that water which is too hot or too cold will prevent the affected person
from flushing the eyes for the full 15 minutes recommended in emergency situations or
on most MSDSs. ANSI Z358.1-2009 provides more specific guidance by recommend-
ing a temperature range of 16-38 degrees Celcius (60-100 degrees Fahrenheit) for
flushing fluid used in all eyewashes and showers.

Inspection
How often must eyewashes and showers be inspected and tested?

OSHA does not prescribe eyewash or shower inspections under 1910.151(c). How-
ever, ANSI Z358.1- 2009 says that all eyewash and shower units be inspected and
maintained in accordance with the manufacturer’s instructions. If the manufacturer
does not prescribe a testing frequency, ANSI says that self-contained units should be
visually inspected weekly to determine if the fluid needs to be changed or more should
be added. Plumbed units should be tested weekly. Running units for at least three
minutes is suggested to reduce microbial contamination.
Do eyewash and shower inspections need to be documented?

There are no recordkeeping requirements with regard to eyewash and shower inspec-
tions. As such, it would be up to an employer to establish a best practice based on the
circumstances found in the workplace and how long other and similar records are kept.
How often do eyewash bottles need to be replaced?

OSHA does not address this issue; therefore, they should be replaced in accordance
with the manufacturer’s instructions.
For combination units, must both the eyewash and shower be functional for use?
ANSI Z358.1-2009 says that components of combination units must operate individu-
ally and simultaneously.
Installation
Is there a specific height at which a plumbed eyewash station must be mounted?

While the OSHA standard is silent, ANSI Z358.1-2009 states that plumbed eyewashes
shall “be positioned with the nozzle(s) not less than 83.8 cm (33 in.) and no greater than
114.3 cm (45 in.) from the level on which the user stands and 15.3 cm (6 in.) minimum
from the wall or nearest obstruction.” Employers should also follow the manufacturer’s
recommended guidelines if provided.

Must eyewashes and showers have a floor drain?

Neither OSHA or ANSI requires that an eyewash or shower be positioned adjacent to
adequate drainage. As such, an employer must evaluate and abate any hazards which
may result. These could include slip, trip, and fall hazards from slippery conditions and
pools of water, environmental contamination depending on the nature of the chemical
being flushed, electrical hazards depending on the location in relation to the eyewash
or shower, etc.
Do older units that don’t meet the requirements in ANSI Z358.1-2009 need to be
replaced?
Yes. OSHA uses the newest version of the ANSI emergency eyewash and shower
standard as an enforcement tool to determine a unit’s “suitability” as required under
1910.151(c). If a unit does not meet the standards outlined by ANSI, then OSHA may
consider the unit to be “unsuitable,” and therefore; in violation of the OSHA standard.
Location
How many eyewashes or showers must an employer have in the workplace?

OSHA does not specify where either an eyewash or shower is needed in a facility.
Rather, the standard requires that, “where the eyes or body of any person may be
exposed to injurious corrosive materials, suitable facilities for quick drenching or flush-
ing of the eyes and body shall be provided within the work area for immediate
emergency use.” Essentially, OSHA expects an employer to determine the level of
potential risk to employees and provide the necessary protection accordingly. What
protection is appropriate should be based on a hazard assessment and the recom-
mendations outlined in ANSI standard Z358.1-2009.
Where must an eyewash or shower be located ?

OSHA requires under 1910.151(c) that emergency eyewashes and showers must be
provided “within the work area for immediate emergency use.” The agency provides no
further details. However, ANSI Z358.1-2009 says that emergency eyewashes and
showers be in accessible locations that require no more than 10 seconds to reach (and
for a strong acid or caustic, the eyewash should be immediately adjacent to the hazard)
and located on the same level as the hazard and that the path of travel be “free of
obstructions that may inhibit its immediate use.” ANSI further states that an average
person covers a distance of approximately 55 feet in 10 seconds when walking at a
normal pace.

How far away does an eyewash or shower need to be from an electrical panel?
OSHA and ANSI only address this issue by saying that emergency flushing facilities
must be in the work area for immediate emergency use and that those facilities must
not take more than 10 seconds to reach from where the hazard is located. ANSI says
that an individual covers approximately 55 feet in that timeframe. As such, an employer
does have some latitude on eyewash and/or shower placement. If the electrical panel
would pose an additional risk due to exposure while using eyewash and/or shower,
then ANSI says it must be relocated or moved.
Maintenance
Can eyewashes be covered to prevent contamination, rust, etc. when not in use?
The ANSI standard says that “nozzles and flushing fluid units must be protected from
airborne contaminants. Whatever means is used to afford such protections, its removal
shall not require a separate motion by the operators when activating the unit.” Covers
cannot be used unless they are specifically designed by and installed to the eyewash
manufacturer’s specifications (e.g., nozzle covers). In other words, a plastic bag,
bucket, shower cap, etc. cannot be placed over the nozzles of an eyewash if it would
require a motion to remove before the eyewash could be activated. Remember, a
user’s hands need to be free to aid in proper flushing or the removal of clothing.
Is a sign required to indicate the location of an eyewash or shower?

OSHA does not address eyewash or shower signs, but ANSI Z358.1-2009 states that
a highly visible sign must be positioned to clearly identify the location of the unit.
Operation
How much water must be delivered via an eyewash or shower while in operation?
An eyewash must supply 0.4 gallons per minute of flushing fluid for at least 15 minutes.
Many self-contained and portable eyewash units only have a capacity of 5 to 10 gallons
for a maximum usefulness of 5 minutes. Squeeze bottles and other personal eyewash
have even lower water capacities. For this reason, the applicable ANSI standard says
that personal wash units (e.g., bottles) do not meet the criteria of plumbed or self-
contained eyewash equipment. As such, personal wash units can provide immediate

flushing to support plumbed or self-contained equipment, but not replace them. Also,
self-contained eyewash equipment that cannot provide the full 15 minutes of required
flushing is also considered supplementary.
Showers must supply 20 gallons of flushing fluid per minute for 15 minutes under all
operating conditions.
What is the height requirement for the water streams coming out of an eyewash
station?
ANSI Z358.1-2009 says that eyewash flushing fluid (plumbed and self-contained units)
must cover the areas between the interior and exterior lines of the gauge at some point
less than 8 inches above the eyewash nozzle.
Types
What does “plumbed” mean?

The definition of a “plumbed” unit per ANSI Z358.1 is “equipment that is connected to
a continual source of potable water.” Simply, it means that it is hooked up to a plumbing
source.
Are eyewash bottles acceptable?

While OSHA does not address this issue, ANSI Z358.1-2009 says that eyewashes (and
showers) must provide a minimum 15 minute irrigation period. For this reason, the
standard states that portable eyewash stations (e.g., bottles, canisters) do not meet the
criteria of plumbed or self-contained eyewash equipment; and therefore, can be used
to support plumbed and self-contained equipment but cannot replace them. In other
words, portable units can be used until an employee can reach a plumbed or self-
contained unit for effective flushing in the immediate work area.
The reason for this is that portable units do not have the capacity to provide the
required 15 minutes of flushing time per the ANSI standard. For example, a one gallon
portable eyewash unit is only going to supply the required flow rate for approximately
2 1⁄2 minutes. Even a 4.5 gallon portable unit would provide a longer flushing time, but
still not at the required 1.5 liters per minute (0.4 gallons) for 15 minutes. And eyewash
bottles have a much smaller capacity.
OSHA does use the ANSI standard when evaluating the “suitability” of eyewashes (and
showers) during inspections in accordance with the requirement under 1910.151(c).
OSHA issued a citation to a company in 2011 that resulted in a $5500.00 “serious”
violation due to the employer not providing employees “with an adequate emergency
eyewash with a large enough volumne in the event of an emergency.”

Are faucet mounted eyewashes compliant?

These types of eyewashes may not meet OSHA requirements for the following rea-
sons:
Activation — The applicable ANSI standard, Z358.1-2009, to which OSHA refers
employers and uses to determine compliance says that plumbed or self-contained
eyewashes must be designed, manufactured, and installed in such a manner that
requires:
1. Activation from “off” to “on” in one second or less, and
2. Operation without the use of the operator’s hands once activated.
Flow rate — An eyewash must be capable of delivering flushing fluid to the eyes at a
rate of .4 gallons per minute for 15 minutes per the ANSI standard. This requirement
would not be met if an employee was expected to fiddle with the knobs of a faucet to
manually regulate the flow rate of the eyewash station. How would the user know
precisely to what position to turn the handle(s) to ensure it meets this requirement?
Temperature — Once activated, the user must be able to use the eyewash without
being required to adjust the handle(s) of the faucet. As such, the faucet itself may not
be able to constantly deliver tepid fluid without manual adjustment. Therefore, a mixing
valve on the faucet or corresponding plumbing may be necessary to deliver flushing
fluid within the recommended temperature range of 60 to 100 degrees Fahrenheit when
the faucet can deliver only hot or only cold water.
If an employer has a faucet mounted eyewash, it must be inspected to ensure it meets
the ANSI standard as stated above.

Reserved

Ergonomics
Lifting
What are the basics of good lifting?

The basic rules of good lifting are:
• Size up the load. Test the weight by lifting one of the corners or pushing on it.
• Place feet close to the object.
• Center the body over the load.
• Bend at the knees.
• Get a good hand-hold.
• Lift straight up letting the legs do the work.
• Do not twist and avoid sudden movements while moving the load.
• Set the load down letting the legs do the work.
Some additional lifting tips include:
• Clear a path of travel.
• Split the load into several small ones, employ the help of another work, or use
a mechanical aid if the load is too large or heavy.
• Push a load on a cart or dolly; do not pull it.
Is there a maximum allowable weight that an individual can lift?

OSHA does not have a regulation that addresses weight restrictions for manual lifting.
OSHA has, however, used the NIOSH Lifting Equation to evaluate manual lifts during
a workplace inspection. The NIOSH equation sets a fixed weight of 51 lbs. as the load
constant (that is generally considered the maximum load nearly all healthy workers
should be able to lift under optimal conditions.) However, the NIOSH equation also
uses other factors such as height and angle of the lift, frequency of the lift, type of hand
grip, and travel distance; these are all as important in assessing a lift as the weight of
the object.
An alternative guide that focuses on male/female population percentages capable of
performing a lift with certain characteristics, rather than on maximum weight limits, is
the Liberty Mutual Material Handling tables. And Oregon OSHA has a tool that provides
a fairly quick and user-friendly way to assess lifts. Employers might also find it helpful
to look at OSHA’s resources for conducting ergonomics analyses which contain links to
3/14 Ergonomics–1
several tools, including a document from Washington State OSHA that contains a
Lifting Hazard Assessment Worksheet based on the 1991 NIOSH Revised Lifting
Equation.
Beyond this information, employers may want to contact an ergonomist for guidance on
the specific operation in question.
Musculoskeletal Disorders (MSDs)
What activities should be avoided to help prevent MSDs?

Prevention is the most important strategy for dealing with work-related musculoskeletal
problems. Some postures to avoid include:
• Prolonged or repetitive flexion or extension of the wrist.
• Prolonged or repetitive bending at the waist.
• Prolonged standing or sitting without shifting your position.
• Suspending an outstretched arm for extended periods of time.
• Holding or turning the head consistently to one side.
• Any unnatural posture that is held repeatedly or for a prolonged time.
Some motions which should be avoided include:
• Repeated motions without periods of rest.
• Repeated motion with little or no variation.
• Repeated motions performed with great force.
• Resting or compressing a body part on or against a surface.
• Lifting heavy objects far away from the body.
• Frequent reaching or working above shoulder height.
What factors may contribute to symptoms of MSDs?

Each person has physical limits, or a “comfort zone,” of activities and work levels they
can tolerate without developing symptoms of MSDs. Some factors which may contrib-
ute to MSD symptoms include:
• Furniture designs or a work area arrangement which produces bad postures.
• Physically demanding work which employees are not accustomed to doing.
• Workers who are generally out of shape.
• Underlying arthritis.
• Diminished muscle strength or joint flexibility.
2–Ergonomics 3/14
How can an employer determine if an MSDs is work-related?

Not all MSDs are work-related. MSDs can and do develop outside the workplace. The
determination of whether any particular MSD is work-related may require the use of
different approaches tailored to specific workplace conditions and exposures. Broadly
speaking, establishing the work-relatedness of a specific case may include:
• Taking a careful history of the patient and the illness,
• Conducting a thorough medical examination, and
• Characterizing factors on and off the job that may have caused or contributed
to the MSD.
How can employers prevent MSDs in their workplace?

A good plan starts with employee involvement. Employers and employees can work
together effectively to reduce work-related MSDs. Here are some ways:
• Look at injury and illness records to find jobs where problems have occurred.
• Talk with workers to identify specific tasks that contribute to pain and lost
workdays.
• Ask workers what changes they think will make a difference.
• Encourage workers to report MSD symptoms and establish a medical man-
agement system to detect problems early.
• Find ways to reduce repeated motions, forceful hand exertions, prolonged
bending, or working above shoulder height.
• Reduce or eliminate vibration and sharp edges or handles that dig into the
skin.
• Rely on equipment (not backs) for heavy or repetitive lifting.
Simple solutions often work best. Workplace changes to reduce pain and cut the risk
of disability need not cost a fortune. For example:
• Change the height or orientation of the product or use tools with handles
designed so that workers won’t have to bend their wrists unnaturally to use the
tool.
• Offer workers involved in intensive keyboarding more frequent short breaks to
rest muscles.
• Vary tasks of assembly line workers to avoid repeated stress for the same
muscles.
• Provide lifting equipment so workers won’t strain their backs. Lifting equip-
ment is available for everything from boxes and crates to nursing home
patients.
3/14 Ergonomics–3
Does OSHA allow the use of back belts?

Both OSHA and The National Institute for Occupational Safety and Health (NIOSH)
have said that there is insufficient evidence to recommend the use of back belts as a
back injury prevention measure. In fact, if workers falsely believe they are protected
when wearing belts, they may attempt to lift more than they would without a belt, posing
a risk of injury to the worker. If employers want to employ the use of back belts, they
should consult a medical professional or an ergonimist for additional information.
Can employees use wrist supports on the job?

In the preamble to OSHA’s proposed ergonomics rule, the agency said that wrist
braces/splints are not considered PPE and are not considered a control to reduce
ergonomic hazards. OSHA noted that these devices are marketed as equipment that
can prevent MSDs, although the evidence to support these claims is not available.
Specifically, the agency said that wrist splints and braces present even more serious
problems:
“Wrist splints or braces used to keep the wrist straight during work are not recom-
mended, unless prescribed by a physician for rehabilitation. * * * using a splint to
achieve the same end may cause more harm than good since the work orientation may
require workers to bend their wrists. If workers are wearing wrist splints, they may have
to use more force to work against the brace. This is not only inefficient, it may actually
increase the pressure in the carpal tunnel area, causing more damage to the hand and
wrist (Ex. 26-1424).”
Since most employers have an injury/illness reporting requirement, employees should
have informed the company if they are having issues with wrist/back pain, at which
point an ergonomics assessment could be performed. If employees are experiencing
issues such as wrist pain, it may be better for the company (and the employee) to send
the employee for an ergonomic medical evaluation, and make a determination whether
there are problems or not.
4–Ergonomics 3/14
Work Stations
At what height should machinery and equipment be set?

There are quite a few variables in terms of what is proper work height (e.g., type of work
being performed) and no specific OSHA standard. However, NIOSH recommends that,
for standing work, to achieve proper posture work surface heights should be:
• Above elbow height for precision work (37-43 inches from the floor);
• Just below elbow height for light work (34-37 inches from the floor); and
• Four to six inches below elbow height for heavy work (28-35 inches from the
floor).
Also, keep in mind that in some cases the height of the work being performed must be
scrutinized versus the height of the work surface. Ideally, if multiple people work on a
machine or work station, there would be a way to adjust the height of either of the
machine or the person. Beyond this information, employers may want to contact an
ergonomics professional for guidance based on the specific tasks their workers will be
performing.
What are lifting tables?

Lifting tables are tables or platforms with spring-like mechanisms allowing the table top
to raise or lower, often dependent on the amount of material placed on the top. These
tables bring materials to waist level to reduce bending, stooping, or twisting move-
ments.
3/14 Ergonomics–5
Reserved
6–Ergonomics 3/14
Exit Routes
Access
Where does an exit route start?

OSHA defines an exit route as “a continuous and unobstructed path of exit travel from
any point within a workplace to a place of safety.”
What is the required width of an exit route?

At 1910.36(g)(2) OSHA states that “an exit access must be at least 28 inches (71.1 cm)
wide at all points.” [bold emphasis added] OSHA defines an exit access as “that
portion of an exit route that leads to an exit.” This would include aisles, doorways,
hallways, ramps, passageways, etc. that may be used to get to an exit.
OSHA further addresses this issue in several Letters of Interpretation (LOI). In the first,
dated April 27, 2000, an employer asks whether or not the minimum width of any way
of exit access must be at least 28 inches in width. OSHA response is ‘yes’. Also, in a
November 15, 1993 LOI in which a company asks whether the width of a doorway that
is 27 5/8 inches wide is in compliance with the above requirement, OSHA’s response
is that “...the deficit of 3/8 inch (0.9 cm) in width would be considered a de minimis
violation having no adverse impact on the safety and health of employees.”
Design
How many exit routes are required in a workplace?

Both OSHA and NFPA 101-2009, “Life Safety Code,” require that at least two exit
routes be available in a workplace to permit prompt evacuation (with the exception
noted in 1910.36(b)(3)). Specifically, 1910.36(b) requires exit routes “be located as far
away as practical from each other so that if one exit route is blocked by fire or smoke,
employees can evacuate using the second exit route.” Keep in mind that an exit route
consists of three parts: Exit access, the exit, and the exit discharge.
If, for example, there is one aisle (the exit access) leading to the exit and discharge,
would employees be able to access another exit and discharge if it were blocked by fire
or smoke? If not, then an employer would have to provide a second exit access as a
way for employees to exit the building as required above.
3/13 Exit Routes–1

Doors
May an overhead door, such as in a warehouse, be used as an exit?

Revolving, sliding, and overhead doors are prohibited from serving as exit doors.
Specifically, at 1910.36(e) OSHA says that a side-hinged door must be used to connect
any room to an exit route. No other type of door is acceptable under the standard.
May a door equipped with a fire door and a fusible link be used as an exit?
These types of doors may not be marked as an exit and used as a means of egress.
If, during an emergency (i.e., a fire), the door was activated via the fusible link and
closed over the regular door, employees could not escape. This would be a violation of
1910.36(d)(2) which states, “exit route doors must be free of any device or alarm that
could restrict emergency use of the exit route...”
Can exit doors be locked if employees are trained on how to open them?
No. OSHA requires under 1910.36(d) that “employees must be able to open an exit
route door from the inside at all times without keys, tools, or special knowledge.” [bold
emphasis added] OSHA further emphasizes this requirement in a December 19, 1991
Letter of Interpretation that clearly states exit doors must not be locked or obstructed
in any way or at any time.
Which way must exit doors open?

Door(s) that “connect any room to an exit route must swing out in the direction of exit
travel if the room is designed to be occupied by more than 50 people or if the room is
a high hazard area...” at 1910.36(e)(2).
Must exit doors be numbered?

OSHA does not require exit doors to be numbered; however, numbering doors is an
effective means of directing people or services (e.g., fire and police departments) to a
particular location at a facility.
2–Exit Routes 3/13

Lighting
How bright must exit signs be?

OSHA requires at 1910.37(b)(6) that each exit sign “be illuminated to a surface value
of at least five foot-candles by a reliable light source.” In addition, self-luminous or
electroluminescent signs that have a minimum luminance surface value of at least .06
footlamberts (0.21 cd/m2) are permitted. In other words, exit signs don’t necessarily
need to be illuminated with a bulb, but must be illuminated to the five foot candle
requirement.
Must exit signs be lit by emergency lighting in the event of a power failure or other
emergency?
OSHA requires at 1910.37(b)(6) that each exit sign “be illuminated to a surface value
of at least five foot-candles by a reliable light source.” If emergency lighting provides the
necessary illumination then that is all that is needed. However, if emergency lighting
were to fail, and the exit signs were not properly illuminated, then the employer would
be in violation of the standard.
Does a map of designated evacuation routes need to be posted?

There are no OSHA requirements to post evacuation signs. However, OSHA CPL
2-1.037 does say that “The use of floor plans or workplace maps which clearly show the
emergency escape routes should be included in the emergency action plan.” This
statement is also in the non-mandatory appendix to Subpart E, “Exit Routes, Emer-
gency Action Plans, and Fire Prevention Plans.”
While maps are not specifically required, many employers often use an exit route map
in an effort to meet the requirements outlined at 1910.38(c)(2), which requires employ-
ers who must have an emergency action plan to include written procedures for
emergency evacuation, “including type of evacuation and exit route assignments.”
Also, local building and fire codes may dictate if and where such maps must be posted.
As such, employers should consult local fire authorities. In addition, a company’s
liability insurance carrier may have requirements on how and where to post maps.
Do doors that are not an exit need to be marked?

At 1910.37(b)(5), OSHA says “each doorway or passage along an exit access that
could be mistaken for an exit must be marked “Not an Exit” or similar designation, or be
identified by a sign indicating its actual use (e.g., closet).”

Do floors need to be marked to indicate the path of exit route travel?

OSHA does not require floor markings to indicate exits or ways of exit access. If an
employer chooses to install exit route floor markings, the American National Standards
Institute (ANSI) Z535.1-1998, “Safety Color Code,” recommends the color green to
indicate evacuation routes. In contrast, the standard recommends black, white, yellow,
or a combination of black and yellow for housekeeping markings.
Note: ANSI Z535.1-2002, “Safety Color Code,” and later editions no longer indicate
safety color meanings, which only appeared in the 1998 and earlier editions.
Obstructions
Is a conveyor with a gate that must be lifted to access an exit route considered an
obstruction?
OSHA states at 1910.37(a)(3) that “exit routes must be free and unobstructed. No
materials or equipment may be placed, either permanently or temporarily, within the
exit route.” OSHA defines an exit route as “a continuous and unobstructed path of exit
travel from any point within a workplace to a place of safety.” [bold emphasis added]
The NFPA 101-2009, “Life Safety Code,” also says that an exit discharge must be free
and unobstructed.
Signs
Do exit signs have to be red and white?

The color of exit signs is addressed in a September, 14, 1972 Letter of Interpretation
in which OSHA says “any color, or color combinations, that is readily visible or distinc-
tive in appearance on exit signs is acceptable to OSHA. It is possible that local building
codes may require a certain color, but our standards do not.”
Also, 1910.35 allows for employers to comply with the exit route provisions of NFPA
101-2009, “Life Safety Code.” According to this standard, “externally illuminated signs
shall...have a [color] contrast ratio of not less than 0.5...Colors providing a good con-
trast are red or green letters on matte white background. Glossy background and
glossy letter colors should be avoided...”
At what height must exit signs be located?

OSHA does not specify the height at which an exit sign must displayed. The require-
ment at 1910.37(b)(2) does state, however, that the sign must be “clearly visible.”
Typically, exit signs are placed above the corresponding exit door. Also, specific place-
ment may be dictated by your local fire code.

Must exit signs be visible from all points in a workplace?

OSHA says at 1910.37(b)(4) that “if the direction of travel to the exit or exit discharge
is not immediately apparent, signs must be posted along the exit access indicating the
direction of travel to the nearest exit and exit discharge. Additionally, the line-of-sight to
an exit sign must clearly be visible at all time.”

Reserved

Extension Cords
Assembly
Can employers make their own extension cords?

Normally, electrical equipment must be approved as an assembly by a nationally-
recognized testing laboratory to be acceptable under OSHA standards. However, under
limited circumstances, OSHA allows employers to make extension cords if a qualified
employee does the work and the cord is equivalent to those that are factory assembled
and approved.
To meet existing electrical standards, ensure shop-made cords contain components
that are:
• Approved for use by a nationally recognized testing laboratory, and
• Compatible for use with the other components of the completed assembly.
Also, the wiring of the completed assembly must be inspected by a qualified person
before the extension cord is initially used. The following checks and tests, or equivalent,
should be performed:
• Determine that all equipment grounding conductors are electrically continu-
ous.
• Test all equipment grounding conductors for electrical continuity.
• Determine that each conductor is connected to its proper terminal and is
properly secured.
• Test each receptacle and attachment plug to ensure correct attachment and
continuity of each conductor.
Inspection
When do cords need to be inspected?

The inspection of cords is covered in 1910.334(a)(2). A visual inspection must be done
before use on any shift for external defects (e.g., loose parts, deformed and missing
pins, or damage to outer jacket or insulation) and for evidence of possible internal
damage (e.g., pinched or crushed outer jacket). Those cords which remain connected
once they are put in place and are not exposed to damage don’t need to be visually
inspected until they are relocated.
9/12 Extension Cords–1

Those cords found to be damaged or defective must not be used until repaired or
replaced.
Power Strips
Is it acceptable to use power strips?

There are no specific regulations governing power strips; however, OSHA does
address this issue in a November 18, 2002 Letter of Interpretation which says:
“OSHA’s standard at 1910.303(b)(2), “Installation and Use,” requires that “Listed or
labeled equipment shall be installed and used in accordance with any instructions
included in the listing or labeling.” Manufacturers and nationally recognized testing
laboratories determine the proper uses for power strips. For example, the UL Directory
contains instructions that require UL-listed RPTs to be directly connected to a perma-
nently installed branch circuit receptacle; they are not to be series-connected to other
RPTs or connected to extension cords. UL also specifies that RPTs are not intended for
use at construction sites and similar locations.
“Power strips are designed for use with a number of low-powered loads, such as
computers, peripherals, or audio/video components. Power loads are addressed by
1910.304(b)(2), Outlet devices: “Outlet devices shall have an ampere rating not less
than the load to be served.” Power strips are not designed for high power loads such
as space heaters, refrigerators and microwave ovens, which can easily exceed the
recommended ampere ratings on many power strips. They must also meet the require-
ments of 1910.305(g)(1), Use of flexible cords and cables. For example, the flexible
power cord is not to be routed through walls, windows, ceilings, floors, or similar
openings.”
Repair
Do damaged extension cords need to be replaced?

Superficial nicks or abrasions — those that only slightly penetrate the outer jacket of an
extension cord and do not permit the cord to bend more in that area than in the rest of
the cord — are not considered a safety concern according to OSHA. Therefore, there
is no need to repair or replace such a cord.
Repair or replacement of an extension cord, depending on its gauge, is required when
the outer jacket is penetrated enough to cause that part of the cord to bend more than
the undamaged part or penetrated completely, or when the conductors or their insula-
tion inside are damaged. When repaired, the cord must be in the same condition as
when it was new with regard to both design and safety.
2–Extension Cords 9/12

Can tape be used to repair damaged extension cords?

While taping nicks or abrasions does not necessarily violate any OSHA standard, the
agency recommends that employers not tape this type of damage for two reasons:
1. OSHA standards preclude using approved electrical conductors and equip-
ment if their characteristics are significantly altered. Applying electrical tape
that is too thick or applying too much of it could change the cord’s original
flexibility and lead to internal damage.
2. The depth of the abrasions and cuts cannot be monitored to see if they get
worse without removing the tape.
Tape repairs of the jacket may not be used to bring a worn or frayed cord into com-
pliance as it can compromise both the design and safety of the cord. For example,
taping can change the flexibility characteristics of the cord, which in turn can affect the
amount of stress in the adjacent areas. This is of particular concern with respect to the
grounding wire.
Also, taped repairs usually will not duplicate the cord’s original characteristics; in most
cases neither the jacket’s strength nor flexibility characteristics will be restored.
Temporary Wiring
What are the requirements for temporary wiring?

OSHA regulates temporary wiring at 1910.305, “Wiring Methods, Components, and
Equipment for General Use.” Approved extension cords are only allowable in the work-
place as temporary wiring. When used for this circumstance, extension cords may be
run through doorways, windows, or similar openings if they are protected from damage.
They can be used for no more than 90 days for temporary use.
Use
Can employers only use approved extension cords?

The use of unapproved extension cords is a violation of both OSHA and National Fire
Protection Association codes. As such, cords must be properly approved by a recog-
nized testing laboratory (e.g., Underwriters Laboratory).
9/12 Extension Cords–3

What uses of extension cords are prohibited?

Improper use of overloaded, unapproved extension cords can present a serious fire
safety hazard in the workplace. As such, inappropriate use of extension cords would
include:
• Using as permanent wiring,
• Using unapproved extension cords,
• Daisy chaining, and
• Using one surge protector/power strip to power another.
Extension cords may only be used in continuous lengths without splice or tap. Hard-
service cord and junior hard-service cord No. 14 and larger may be repaired if spliced
so that the splice retains the insulation, outer sheath properties, and usage character-
istics of the cord being spliced.
Also, extension cords must be connected to devices and fittings so that strain relief is
provided that will prevent pull from being directly transmitted to joints or terminal
screws.
Is a GFCI required for fans that are temporarily connected to an extension cord?
Plugging the cord of the fan into an extension cord which is then plugged into the
permanent wiring of the building that has grounding protection in the outlet would seem
to provide adequate protection, but since that extension cord is considered to be
temporary wiring, the fan would need a GFCI per 1910.304(b)(3)(ii).
However, OSHA discusses this topic in a December 21, 1999 Letter of Interpretation
which says:
“For example, if a GFCI-type receptacle is used, it must be visibly marked “No Equip-
ment Ground,” and equipment required to be grounded may not be used in the
ungrounded, GFCI-type receptacle. However, many appliances (i.e., lamps; toasters;
televisions; double insulated appliances) and tools (i.e., double insulated tools; tools
supplied with a low voltage isolating transformer) are not required to be grounded and
they may be used in an ungrounded, GFCI-type receptacle. The GFCI feature of these
GFCI-type receptacles provides additional electrocution protection in the event of mis-
use (i.e., a floor buffing machine is powered by a 3-prong plug from a properly marked
and wired ungrounded, GFCI-type receptacle).”
4–Extension Cords 9/12

Eye and Face Protection
Contact Lenses
Are contact lenses allowed?

OSHA believes that contact lenses do not pose additional hazards to the wearer. The
agency says, however, that contact lenses are not eye protective devices. If eye haz-
ards are present, appropriate eye protection must be worn instead of, or in conjunction
with, contact lenses.
Eyeglasses
Are prescription eyeglasses considered appropriate eye protection?

No. Eyeglasses designed for ordinary wear do not provide the level of protection
necessary to protect against workplace hazards.
Can employees wear eyeglasses while wearing eye and face protection?
Yes, but special care must be taken when choosing eye protection for employees who
wear eyeglasses with corrective lenses, such as the following:
• Prescription spectacles, with side shields and protective lenses meeting the
requirements of ANSI Z87.1, that also correct the individual employee’s vision.
• Goggles that can fit comfortably over corrective eyeglasses without disturbing
the alignment of the eyeglasses.
• Goggles that incorporate corrective lenses mounted behind protective lenses.
Must an employer pay for prescription safety glasses?

An employer is required to pay for prescription safety glasses if they:
• Do not provide non-prescription safety eyewear that fits comfortably over
regular glasses, or
• Do not allow employees to take prescription safety glasses off of the job-site.
Employers are also required to pay for specialty prescription safety eyewear, such as
lens inserts into full facepiece respirators (when the employee does not wear contact
lenses).
3/14 Eye and Face Protection–1

Maintenance and Care
What maintenance and care is required for eye and face protection?
It is important that all eye and face protection be kept clean and properly maintained.
Cleaning is particularly important where dirty or fogged lenses could impair vision. Eye
and face protection should be inspected, cleaned, and maintained at regular intervals
so that equipment provides the requisite protection.
It is also important to ensure that contaminated equipment which cannot be decon-
taminated is disposed of in a manner that protects employees from exposure to
hazards.
What is the proper way to store eye and face protection?

Goggles should be kept in a case when not in use. Spectacles, in particular, should be
given the same care as one’s own glasses, since the frame, nose pads, and temples
can be damaged by rough usage. After disinfecting eyewear, the dry parts or items
should be placed in a clean, dust-proof container, such as a box, bag, or plastic
envelope to protect them until reissue.
Must eye and face personal protection be marked?

Yes, eye and face personal protective equipment (PPE) must be marked permanently
and legibly by the manufacturer, so that it can be easily identified. The mark cannot
interfere with the wearer’s vision.
Selection
When must eye and face protection be provided to employees?

OSHA’s eye and face protection standard at 1910.133 requires the use of eye and face
protection when workers are exposed to eye or face hazards such as flying objects,
molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or
potentially injurious light radiation. It must be provided if work practice or engineering
controls do not eliminate the risk of injury from such hazards.
2–Eye and Face Protection 3/14

Are there certain jobs that require eye and face protection?
OSHA does not specify which jobs require the use of safety glasses or other types of
PPE as it’s up to the employer to provide appropriate protection based on the results
of the hazard assessment.
However, OSHA does provide some guidance to employers in “Appendix B to Subpart
I to Part 1910 — Non-Mandatory Compliance Guidelines for Hazard Assessment and
Personal Protective Equipment Selection,” which includes the following:
“Some occupations (not a complete list) for which eye protection should be routinely
considered are: carpenters, electricians, machinists, mechanics and repairers, mill-
wrights, plumbers and pipe fitters, sheet metal workers and tinsmiths, assemblers,
sanders, grinding machine operators, lathe and milling machine operators, sawyers,
welders, laborers, chemical process operators and handlers, and timber cutting and
logging workers. ...”
The Appendix also includes an eye and face protection selection chart which may be
helpful to employers.
What type of protection must be used?

Eye and face protection must be selected based on the hazards to which the worker is
exposed (i.e., impact, penetration, compression, chemical, heat, harmful dust, light
radiation, or combination) and must comply with any of the following consensus stan-
dards:
• ANSI Z87.1-2003, “American National Standard Practice for Occupational
and Educational Eye and Face Protection,” which is incorporated by reference
in 1910.6;
• ANSI Z87.1-1989 (R-1998), “American National Standard Practice for Occu-
pational and Educational Eye and Face Protection,” which is incorporated by
reference in 1910.6; or
• ANSI Z87.1-1989, “American National Standard Practice for Occupational
and Educational Eye and Face Protection,” which is incorporated by reference
in § 1910.6.
ANSI-approved safety glasses are marked “Z87” on the frames and lenses.
Can face shields be used instead of safety goggles?

Face shields alone do not protect employees from impact hazards. Face shields are
considered secondary protectors and may only be used in combination with safety
goggles or spectacles. This provides a higher level of protection for employees’ face
and eyes.

Training
What training is required before eye and face protection can be used?
Training must be provided to employees who are required to use eye and face pro-
tection and include the following:
• When eye and face protection is necessary;
• How improper fit, use, or maintenance can compromise its protective effects;
• Limitations and capabilities of the eye and face protection;
• How to properly don, doff, adjust, and wear the protection; and
• Proper care, maintenance, useful life, and disposal.
A record of this training must be kept that contains:
• The name of each employee who received the training,
• The date(s) of the training, and
• Information that identifies the subject covered during the training.
Use
Can eye protection be shared among employees working on different shifts?

Yes; however, shared eye protection must be disinfected after each use. If goggles or
spectacles do not have to be individually designed to incorporate an employee’s cor-
rective lenses, and you disinfect the eyewear between uses by different employees,
more that one employee may use the same set of protective eyewear.
Welding
Must welders wear safety glasses under their welding helmets?

Yes. The face shield or helmet protects the wearer from the welding glare, but does not
protect the wearer from sparks produced by the welding. Additional eye protection is
required.
ANSI/ASC Z49.1-88 states, in part, that “Helmets or hand shields with filter lenses . .
. shall be used by operators . . . Safety spectacles with side shields, goggles or other
suitable eye protection shall also be worn.”

How dark do the lenses on welding helmets and safety goggles need to be?
The intensity of light or radiant energy produced by welding, cutting, or brazing opera-
tions varies according to a number of factors including the task producing the light, the
electrode size, and the arc current. To protect employees who are exposed to intense
radiant energy, begin be selecting a shade too dark to see the welding zone. Then try
lighter shades until one is found that allows a sufficient view of the welding zone without
going below the minimum protective shade.

Reserved

F/G
Table of Contents
Fall Protection ...................................................................................... 1

Height............................................................................................. 1
Loading Docks ................................................................................. 1
Personal Fall Protection Systems......................................................... 1
Portable Ladders .............................................................................. 2
Rolling Stock.................................................................................... 2
Roofs ............................................................................................. 3
Safety Chains .................................................................................. 3
Swinging Gates ................................................................................ 4
Fire Prevention Plans ............................................................................ 1
Applicability ..................................................................................... 1
Evacuation ...................................................................................... 1
Fire Prevention Plan .......................................................................... 2
Notification ...................................................................................... 3
Training........................................................................................... 4
First Aid ............................................................................................... 1
Applicability ..................................................................................... 1
Bloodborne Pathogens....................................................................... 1
Cardiopulmonary Resuscitation (CPR) .................................................. 2
Certification ..................................................................................... 2
Emergency Response........................................................................ 2
Responders ..................................................................................... 4
Training........................................................................................... 5
First Aid Kits ........................................................................................ 1
Inspection........................................................................................ 1
Location .......................................................................................... 1
Log ................................................................................................ 2
Quantity .......................................................................................... 2
Securement ..................................................................................... 2
Supplies .......................................................................................... 3
Fixed Ladders ....................................................................................... 1
Cages and Wells .............................................................................. 1
3/14 F/G–1
Construction .................................................................................... 1
Fall Protection .................................................................................. 2
Inspection........................................................................................ 2
Platforms......................................................................................... 3
Retrofitting ....................................................................................... 3
Flammable Liquids ................................................................................ 1
Bonding and Grounding ..................................................................... 1
Cabinets ......................................................................................... 2
Containers ....................................................................................... 4
Definitions ....................................................................................... 4
Gasoline ......................................................................................... 5
Storage ........................................................................................... 6
Transfer .......................................................................................... 7
2–F/G 3/14
Fall Protection
Height
At what height is fall protection required in general industry?

OSHA requires at 1910.23(c) that fall protection be provided when working four feet or
more above the adjacent floor or ground. This essentially includes all walking-working
surfaces (e.g., roofs, mezzanines, platforms, etc.), except portable ladders and fixed
ladders 20 feet or less in unbroken length. The required fall protection is a standard
railing as outlined in 1910.23(e).
Loading Docks
Is fall protection required for loading docks?

OSHA considers loading docks a platform. Under 1910.23(c), “Protection of open-sided
floors, platforms, and runways,” the agency requires that every open-sided floor or
platform four feet or more above the adjacent floor or ground level be guarded by a
standard railing or the equivalent as specified in 1910.23(e)(3). [bold emphasis added]
A standard railing as defined under 1910.23(e) must consist of a top rail, midrail, and
posts and have a vertical height of 42 inches nominal from the upper surface of the top
rail to the platform.
Employers would not, however, need to install a standard railing if the doorway was
equipped with a door and it was kept closed at all times when not in use.
Personal Fall Protection Systems
How often do body harnesses and lanyards need to be inspected?

Although there is no general industry OSHA standard that specifically addresses safety
harness/lanyard inspections, Appendix C to 1910.66, “Personal Fall Arrest System
(Section I-Mandatory; Sections II and III-Non-Mandatory)” states, “Personal fall arrest
systems shall be inspected prior to each use for mildew, wear, damage and other
deterioration, and defective components shall be removed from service if their strength
or function may be adversely affected.” Further, 1910.132(d) says that, “defective or
Fall Protection–1
damaged personal protective equipment shall not be used.” Also, the manufacturer
may also have specific maintenance or care instructions and/or recommended guide-
lines regarding the longevity and use of the harness/lanyard.
Portable Ladders
Is fall protection required when using a portable ladders?

OSHA currently does not require fall protection when using portable ladders in general
industry. However, the agency addresses this issue in several Letters of Interpretation
(LOI). As stated in a January 13, 2000 LOI, if the user is at risk of falling from a portable
ladder OSHA encourages employers to provide additional fall protection. There are a
number of factors to consider in these situations, including the height of the ladder and
the limitations of the fall arrest system used. OSHA further addresses this issue, with
specific regard to stepladders, in a November 28, 2007 LOI.
Although both of these LOIs are in specific relation to the construction standards, the
information provided should provide helpful guidance to general industry employers.
Rolling Stock
Is a driver required to wear fall protection when working on top of a trailer?

OSHA currently says is that fall protection is generally not required when working on
top of “rolling stock” (i.e., flat bed trucks/trailers) unless employees are working atop
stock that is positioned inside of or contiguous to a building or other structure and fall
protection could be installed, as outlined in an October 18, 1996 Letter of Interpretation.
Specifically, OSHA says that employers would not be cited under Subpart D, “Walking-
Working Surfaces.” However, the letter also says that The General Duty Clause
requires an employer to provide employees with a workplace that is free from hazards
that are recognized by the employer’s industry and that are likely to cause death or
serious physical harm. Thus, where feasible means exist to eliminate or materially
reduce the hazard, a citation can be issued for a General Duty Clause violation. In other
words, employers need to assess whether fall protection can be used when working on
top of rolling stock. If it can, it must be.
2–Fall Protection
Roofs
What type of fall protection is required on roofs?

In general industry, OSHA considers a roof a platform. As such, employers must pro-
vide fall protection via a guardrail (permanent or temporary) at four feet or above the
ground as prescribed at 1910.23(c). When guardrails aren’t feasible, however, OSHA
says that employers can provide employees with fall restraint (i.e., a safety belt and
lanyard) hooked to an anchorage that will not allow the employees to approach the
edge of the roof as referenced in a May 13, 1980 Letter of Interpretation.
The use of designated areas on roofs are currently not allowed in general industry as
they are in construction.
Is fall protection required when maintenance personnel work on roofs?

If maintenance personnel are engaging in construction activities, then employers would
comply with construction fall protection provisions. For the most part, general industry
employers rarely engage in construction activities as defined under 1926. For example,
sending maintenance personnel up on a roof to work on an air conditioning unit or
remove snow are considered general industry activities and employers would have to
comply with the fall protection requirements outlined under 1910.23. If, on the other
hand, those maitenance personnel were installing a new roof or a new HVAC system,
then they would clearly be engaged in construction activities and would have to comply
with applicable construction requirements accordingly.
Safety Chains
Can safety chains be used for fall protection in lieu of a standard railing?
OSHA does permit the use of safety chains and has addressed the issue in two Letters
of Interpretation (LOI). In the first, dated February 12, 1982, OSHA makes mention of
chains with regard to safety gates by saying, “if in fact the safety chains used for top
and intermediate rails afford employees protection “at least as effective as” the swing-
ing gate, the safety chains would be adequate and noted as a de minimis violation.”
[bold emphasis added] The top rail must have a vertical height of 42 inches nominal
and the intermediate rail must be approximately halfways between the top rail and the
floor as required by 1910.23(d).
In the second LOI, dated June 03, 1983, OSHA says, “as specified in the standard, the
anchoring of posts and installation of chains for railings must be of such construction
that the completed structure shall be capable of withstanding a load of at least 200
pounds applied in any direction at any point on the top rail.” [bold emphasis added]
Fall Protection–3
The requirement is that a guardrail be installed, but safety chains would be permitted
if it was done to mimic a standard railing requirements as stated above. A single chain,
however, would not meet these requirements.
Swinging Gates
What are the construction requirements for a swinging gate?

OSHA does not provide specifics regarding the construction of a gate used as fall
protection in any standard. However, OSHA has recommended that the gate meet the
requirements of a standard railing when closed.
4–Fall Protection
Applicability
Who must develop a fire prevention plan?

OSHA’s Fire Prevention Plan (FPP) standard at 1910.39 applies to those companies
which are required to have a fire prevention plan by one of these standards:
• 1910.1047, Ethylene Oxide (EtO)
• 1910.1050, Methylenedianiline (MDA)
• 1910.1051, 1,3-Butadiene
If an employer has developed a fire safety policy, including an emergency action plan
(EAP) and a FPP in accordance with 1910.39, the employer is exempted from all or
some of the provisions of 1910.157:
• When extinguishers are provided but not intended for employee use, and the
employer has developed an FPP fully meeting the requirements of 1910.39.
• Where portable fire extinguishers are not available and are not required by a
particular OSHA standard, and if the written fire safety policy requires imme-
diate and total evacuation of employees from the workplace upon sounding of
a fire alarm signal.
• Where an employer has:
❍ An FPP which meets 1910.39,
❍ Designates certain employees to be the only ones authorized to use
available portable fire extinguishers, and
❍ Requires all other employees in the fire area to immediate evacuate
the affected work area upon the sounding of a fire alarm.
Evacuation
Does OSHA require fire drills?

OSHA does not require fire drills; however, they are an effective method of training
employees to ensure that everyone knows what they must do in case of an emergency.
As such, employers must consider the benefit of conducting such drills. Keep in mind
3/13 Fire Prevention Plans–1

that while not required, OSHA may cite employers under The General Duty Clause if an
incident were to occur and it could be demonstrated that a fire drill would have pre-
vented it.
Also, fire prevention and response is something that involves local emergency
responders; therefore, coordination with them or a local fire marshal would be consid-
ered a best practice.
How must employees be accounted for after an evacuation?

Accounting for all employees following an evacuation is critical. Confusion in the
assembly areas can lead to delays in rescuing anyone trapped in the building, or
unnecessary and dangerous search-and -rescue operations.
To ensure the fastest, most accurate accountability of employees, consider including
these steps in the EAP:
• Designate assembly areas where employees should gather after evacuating;
• Develop procedures for taking a head count after the evacuation. Identify the
names and last known location of anyone not accounted for and pass this
information to the coordinator;
• Establish a method for accounting for non-employees such as suppliers and
customers; and
• Establish procedures for further evacuation in case the incident expands,
such as sending employees home or providing transportation to an offsite
location.
Fire Prevention Plan
Must a fire prevention plan be written?

Yes, a fire prevention plan must be in writing, kept in the workplace, and available to
employees for review.
What must be covered in a fire prevention plan?

The fire prevention plan must include, but is not limited to:
• A list of all major fire hazards, proper handling and storage procedures for
hazardous materials, potential ignition sources and their control, and the type
of fire protection equipment necessary to control each major hazard;
• Procedures to control accumulations of flammable and combustible waste
materials;
2–Fire Prevention Plans 3/13

• Procedures for regular maintenance of safeguards installed on heat-

producing equipment to prevent the accidental ignition of combustible
materials;
• The name or job title of employees responsible for maintaining equipment to
prevent or control sources of ignition or fires; and
• The name or job title of employees responsible for the control of fuel source
hazards.
Additionally the fire prevention plan may include:
• Emergency escape procedures and route assignments, such as floor plans,
workplace maps, and safe or refuge areas;
• An evacuation policy and procedure, including assembly locations and head
count procedures to account for all employees after an evacuation; and
• Names, titles, departments, and telephone numbers of individuals both within
and outside your company to contact for additional information or explanation
of duties and responsibilities under the emergency plan.
Is a FPP required for each company location?

The fire prevention plan must be tailored to the workplace; therefore, each company
location should have a plan.
Keep a copy of the FPP in a convenient location so that employees can access it, or
provide all employees a copy.
In the event of an emergency, access to employees home telephone numbers, medical
information, etc. may be important. Keep a copy of this information in a secure location
outside of the main facility.
Notification
How must employees be alerted in an emergency?

All employees, including disabled workers, must be alerted to evacuate or take other
action in the event of a fire. As such, the FPP should include:
• A description of alarms used to alert employees to evacuate;
• An explanation of the emergency communications system which will be used
to notify employees and contact local emergency responders; and
• What means will be used to ensure that alarms are heard, seen, or otherwise
perceived by everyone in the workplace, such as an auxiliary power supply in
the event of power failure.
3/13 Fire Prevention Plans–3

How can an alarm system be effective in noisy work areas, or in areas where hearing
impaired employees are working?
Alarm devices are commonly equipped with both visual and audible alarms. A strobe
light can be activated in conjunction with the audible alarm. Employers should contact
an alarm service provider for more information on the type of alarms available, and for
guidance on the optimal placement of alarms in their facility.
Training
How must employees be trained?

An employer must inform employees upon initial assignment to a job of the fire hazards
to which they are exposed. An employer must also review with each employee those
parts of the fire prevention plan necessary for self-protection. This review should be
done when:
• The plan is first developed,
• Employees are initially hired,
• Employees responsibilities under the plan change, and
• The plan is changed.
General training for employees should include:
• Individual roles and responsibilities;
• Threats, hazards, and corrective actions;
• Notification, warning, and communications procedures;
• Means for locating family members in an emergency;
• Emergency response procedures;
• Evacuation, shelter, and accountability procedures;
• Location and use of common emergency equipment; and
• Emergency shutdown procedures.
While annual training is not required, consider a yearly refresher. Offer training after:
• Introducing new equipment, materials, or processes into the workplace that
affect evacuation routes;
• Changing the layout or design of the facility; and
• Revising or updating emergency procedures.
If there are 10 or fewer employees, the EAP may be communicated orally.
Once everyone has been trained, it is a best practice to hold practice drills occasionally.
4–Fire Prevention Plans 3/13

First Aid
Applicability
Does the medical services and first aid standard apply to all types of businesses?
The standard applies to all employers in general industry, regardless of size, except for
state and local government entities and employers that fall under the jurisdiction of
other federal agencies.
Must emergency responders be provided the Hepatitis B vaccine?

An employer must provide Hepatitis B vaccinations, or the declination form, to employ-
ees who will have occupational exposure. OSHA defines “occupational exposure” as
reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood
or other potentially infectious materials that may result from the performance of an
employee’s duties. This would include employees whose written job descriptions or
whose job duties will expose them to blood or other potentially infectious materials on
the job. If all employees that will be trained on first aid and CPR are required (not
volunteers) to be first responders, or will be responsible for cleaning up after an acci-
dent, then they would fall into a bloodborne pathogen (BBP) program.
If any employee responds in the workplace as a “Good Samaritan,” then the employer
would be obliged to offer them the Hepatitis B series.
Does the BBP standard apply to voluntary emergency responders?

No. In an October 22, 1992 Letter of Interpretation (LOI) OSHA states, “…the definition
of “occupational exposure” comprises the reasonable anticipation that the employee
will come into contact with these fluids during the course of performing his or her work
duties....Employees who perform “Good Samaritan” acts are not, per se, covered by
this standard, although OSHA would encourage an employer to offer follow-up proce-
dures to an employee who experiences an exposure incident as the result of
performing a “Good Samaritan” act. This is because such an action does not constitute
“occupational exposure,” as defined by the standard. The key to this issue is not
whether employees have been trained in first aid, but whether they are also designated
as responsible for rendering medical assistance. While many workers may be trained
in first aid and CPR, not all of these employees would necessarily be designated to
render first aid.”
3/14 First Aid –1

Cardiopulmonary Resuscitation (CPR)
Must an employer have personnel trained in CPR?

OSHA does not require, but recommends, that CPR training be part of a first aid
program. However, some OSHA standards (e.g., logging operations (1910.266);
permit-required confined spaces (1910.146); and electric power generation, transmis-
sion, and distribution (1910.269)), require employees be trained in first aid and CPR. If
an employer is covered by one of these specific standards, CPR training would be
required.
Certification
Must emergency responders be certified?

If an employer is required to have employees who are “trained responders” on site per
an applicable standard (e.g., permit-required confined spaces), then they must have
current certifications. Typically, these certifications are administered by the entity which
provides the training (e.g., American Red Cross, American Heart Association, National
Safety Council, etc.). As such, an employer would be expected to follow that entity’s
re-certification schedule as necessary.
Emergency Response
Must an employer have individuals trained to render first aid?

The OSHA requirement at 1910.151(b) states, “In the absence of an infirmary, clinic, or
hospital in near proximity to the workplace which is used for the treatment of all injured
employees, a person or persons shall be adequately trained to render first aid.”
OSHA also requires that adequate first aid supplies be readily available.
What does OSHA mean by “readily available” first aid supplies?

The term “readily available” is not defined in 1910.151; however, according to a April
18, 2002 LOI, OSHA says that the person who has been trained to render first aid must
be able to quickly access the first aid supplies in order to effectively provide injured or
ill employees with first aid attention. The first aid supplies should be located in an easily
accessible area, and the first aid provider generally should not have to travel through
several doorways, hallways, and/or stairways to access first aid supplies.
2–First Aid 3/14

Must employers post emergency numbers near telephones?

According to 1910.165(b)(4), general industry employers must post emergency tele-
phone numbers near telephones, or employee notice boards, and other conspicuous
locations when telephones serve as a means of reporting emergencies.
If an employer is required to complete an emergency action plan under 1910.38, then
that plan must include procedures for reporting a fire or another emergency. It is the
employer’s decision whether or not those procedures may call for employees to refer
to emergency telephone numbers posted near telephones.
Also, state and local fire codes may be more stringent and call for the posting of
emergency telephone numbers.
What does OSHA consider to be “in near proximity to the workplace” with regard to
outside medical assistance?
The phrase “in near proximity to the workplace” does not directly relate to any specific
distance. In medical emergencies, response time is a more relevant measure. Suffi-
cient response time for medical assistance is to be based on an assessment of
workplace hazards and the possible outcomes that could occur.
While OSHA used to use a 3 to 4 minute response time for suffocation, severe bleeding,
or other life threatening injury or illness, and a 15 minute response time for non-life
threatening emergencies, that is not longer OSHA’s policy. In a April 18, 2002 LOI, the
agency says, “As an employer would not know in advance whether a life-threatening
injury would occur, an employer should not use the 15-minute (non-life-threatening)
time frame for determining the quantity and location of first aid supplies; however, the
3–4 minute (life-threatening) time frame would be acceptable.”
Can employers be held liable for the first aid it renders to workers?
OSHA addresses this issue in a December 11, 1996 LOI, which states:
“Question 2: “If an emergency situation were to occur where first aid was necessary
and a trained employee were to panic, forgetting all of their training, and no first aid or
improper first aid was administered could the employer be cited?”
Answer: If a trained employee were to panic in an emergency situation and not
administer first aid or administer improper first aid, OSHA would not cite the employer.
The employer would have met his obligation under the standard by having individuals
trained to render first aid. The standard only requires employees to be trained in first
aid, but does not address the actual performance of first aid in an emergency situation.
Please note, however, that OSHA would conduct an investigation, if deemed neces-
sary, to ensure that proper training certification, e.g., First Aid and CPR certificates
were in order.”
Employees themselves would be covered under a state’s Good Samaritan law if appli-
cable.
3/14 First Aid –3

This does not entirely address the issue of liability, however. A company can be sued
by nearly anyone at nearly anytime for nearly anything. Injuries in the workplace usually
fall under Workers’ Compensation laws though.
Responders
How many emergency responders must we have onsite?

OSHA does not provide any guidance on what would constitute an adequate number
of responders based on the size of the workforce, type of industry, footprint of the
facility, etc. In this case, employers should employ a common sense approach. As
such, an employer must have a sufficient number of individuals to cover all shifts at all
times taking into account vacations, absences from the facility, and so on. Also consider
response times and the size of the facility. If it is a larger layout, and an employer needs
to comply with the 3 to 4 minute response time that OSHA requires, several “teams”
based at various locations within the facility may be necessary.
Also, an employer may find it useful to consult their medical professional or outside first
responders to determine how many responders would be adequate.
How should an employer set up an emergency response team?

An employer must first determine how many people will need to be on the team so that
all locations and shifts can be adequately covered. Then you must determine what level
you wish to train them to (i.e., first aider/CPR/AED, first responders, EMT) and who can
provide that training (e.g., the American Red Cross). Next, determine how the team will
be equipped (e.g., a central location for all equipment and supplies, each team member
will be given their own kit, etc.) Then, schedule occasional drills which address those
accidents that can be reasonably foreseen occurring at the facility. Solicit cooperation
from the local ambulance service, EMTs, or emergency responders, and request their
assistance for ideas on supplies, equipment, number of team members, level of train-
ing, etc.
Can emergency responders be volunteers?

In a May 25, 2004 LOI OSHA states of 1910.151, “The standard, as presently worded,
does not explicitly require that an employee or employees be both trained AND required
by the employer to render first aid. OSHA has chosen to interpret the standard as
imposing a training requirement but not a designation requirement.”
In other words, employers must train employees, but are not required to designate
anyone as a formal responder.
4–First Aid 3/14

Can emergency responders administer oxygen in an emergency?

This is governed by each state. An employer may have to have a physician’s prescrip-
tion to obtain it for the workplace. Responders may also require training and
certification to administer oxygen in an emergency. As such, employers should check
with a local first aid/CPR training provider regarding any state requirements.
Training
What type of training is required for emergency responders?

OSHA does not teach first aid courses or certify first-aid training courses for instructors
or trainees. However, training for first aid is offered by the American Heart Association,
the American Red Cross, the National Safety Council, and other nationally recognized
and private educational organizations. Regardless of who performs the training, first aid
courses should be individualized to the needs of the workplace, and include (at a
minimum) instruction in general and workplace hazard-specific knowledge and skills.
CPR training should incorporate automated external defibrillator (AED) training if an
AED is available at the worksite.
How often should emergency responders receive re-certification training?

First aid responders may have long intervals between learning and using skills. As
such, the American Heart Association’s Emergency Cardiovascular Care Committee
encourages skills review and practice sessions at least every 6 months for CPR and
AED skills. Instructor-led retraining for life–threatening emergencies should occur at
least annually. Retraining for non–life–threatening response should occur periodically.
Does OSHA allow emergency responders to train others in-house?

If an employer is required to have certified emergency responders on site per an
applicable standard (e.g., permit-required confined spaces), then training of other
emergency responders must be done by an organization that can issue such certifi-
cations (e.g., the American Red Cross).
If an employer is not required to comply with one of these standards, then OSHA does
not specify that the trainer be certified. As such, emergency responders can provide
first aid training for all employees. Employers may wish to consult a legal professional,
however, regarding the potential liabilities created by not having designated emergency
responders certified by a recognized organization.
3/14 First Aid –5

Reserved
6–First Aid 3/14

First Aid Kits
Inspection
How often do first aid kits need to be inspected?

The ANSI/ISEA Z308.1-2009 standard states that first aid kits should be regularly
inspected to ensure completeness, condition of supplies, and expiration dates to main-
tain compliance. Expired supplies should be removed and additional quantities should
be added as needed.
Also, OSHA states at 1910.151(b) that “adequate first aid supplies shall be readily
available.” By readily available, OSHA means always available regardless of how often
employers inspect first aid kits. Some employers maintain a check-off list with the kit so
that items can be marked off as they are taken out/used. This may make the task of
keeping track of kit contents easier.
Location
Where must first aid kits be located?

OSHA does not have a requirement that first aid kits be located in specific areas or
every so many feet.
Must first aid kits be mounted on a wall?

Kits are not required to be mounted to walls, although many employers do so to more
easily keep track of the kit and to be able to systematically check contents.
What does OSHA mean by “readily available” first aid supplies?

The term “readily available” is not defined in 1910.151; however, according to a April
18, 2002 Letter of Interpretation (LOI), OSHA says that the person who has been
trained to render first aid must be able to quickly access the first aid supplies in order
to effectively provide injured or ill employees with first aid attention. The first aid sup-
plies should be located in an easily accessible area, and the first aid provider generally
should not have to travel through several doorways, hallways, and/or stairways to
access first aid supplies.
3/14 First Aid Kits –1

Log
Must a first aid log be kept of the number and quantity of supplies?
Neither OSHA nor ANSI requires that employers maintain a first aid log.
Must first aid kits be labeled?

According to ANSI/ISEA Z308.1, each first aid kit and/or location must be visibly
marked as a place where first aid supplies are located.
Quantity
How many first aid kits are needed in a workplace?

OSHA does not require employers to have a certain number of kits in the workplace.
This should be based on several actors including the size of the workplace, number of
employees, likelihood and location of possible accidents, etc. Also, 1910.151(a) states
that the employer must have a medical professional to advise on matters of plant
health, such as what first aid supplies should be available, the amount of supplies
needed, and where those supplies should be placed. In other words, OSHA would
expect employers to consult their medical professional for guidance.
In addition, employers may also discuss this issue with a local ambulance service or
outside emergency responders for suggestions. First aid supply vendors might also be
able to provide specific recommendation for a workplace.
Securement
Can first aid kits or cabinets be locked?

OSHA addresses this issue in a January 23, 2007 LOI in which the agency states, ‘yes,’
first aid cabinets can be locked; however, they must be readily accessible in the event
of an emergency. Locking the cabinet may limit accessibility.” Therefore, employers
2–First Aid Kits 3/14

need to ensure that employees and/or first aid providers/emergency responders can
get to the key and the supplies in an emergency.
Supplies
What supplies must be in a first aid kit?

OSHA requires at 1910.151(b) that “adequate first aid supplies shall be readily avail-
able.” The agency does not and cannot define what constitutes “adequate” since the
needs of each workplace will be unique. However, in Appendix A to 1910.151, OSHA
says that “by assessing the specific needs of their workplace, employers can ensure
that reasonably anticipated supplies are available.” OSHA further requires at
1910.151(a), that an employer have a medical professional to advise on matters of
plant health, such as what first aid supplies should be available.
OSHA’s First Aid Handbook states of workplace first aid supplies that “the supplies
must be adequate, should reflect the kinds of injuries that occur, and must be stored in
an area where they are readily available for emergency access.” This is supported by
a February 02, 2007 LOI which says that “employers are required to provide first aid
supplies that are most appropriate to respond to incidents at their workplaces. OSHA
allows employers to provide first aid supplies specific to the needs of their workplace.”
OSHA also refers employers to ANSI/ISEA Z308.1-2009, “Minimum Requirement for
Workplace First Aid Kits and Supplies.” The standard outlines the minimum quantities
and sizes of both required and recommended supplies considered sufficient for a small
workplace first aid kit. This would include (but is not limited to) absorbent compresses,
adhesive bandages and tape, antibiotic treatment, antiseptic, sterile pads, cold packs,
oral analgesics, etc.
Are over-the-counter (OTC) medications permitted as a first aid supply?

OSHA neither encourages nor discourages employers from dispensing OTC medica-
tions to employees. According to ANSI/ISEA Z308.1-2009, a basic workplace first aid
kit may include oral analgesics packaged in single dose, tamper evident packaging with
full labeling. However, employers should consult their legal professional as state law
and relevant state court cases may impact an employer’s decision. Due to liability
concerns, some employers make certain OTC medications available through a vending
machine.
Do expired supplies need to be replaced?

At 1910.151(b) OSHA states only that “adequate first aid supplies shall be readily
available.” However, ANSI/ISEA Z308.1-2009 says that expiration dates of supplies in
kits should be regularly inspected. If an expired supply is found, ANSI recommends that
is be removed from the kit and replaced.
3/14 First Aid Kits –3

Reserved
4–First Aid Kits 3/14

Fixed Ladders
Cages and Wells
When is a cage required on a fixed ladder?

All fixed ladders of more than 20 feet, to a maximum unbroken length of 30 feet, must
be have a cage or well as required at 1910.27(d)(1)(ii).
At what height must the cage be fixed to a ladder?

The cage must extend down the ladder to no less than 7 feet, but not more than 8 feet,
above the base of the ladder as specified at 1910.27(d)(1)(iv). OSHA does not specify
where the ladder itself must start in relation to the ground. The cage requirement is
specific to the length of the ladder itself, not the start of the climb.
Construction
When must a fixed ladder be used instead of a portable ladder?

OSHA does not specifically prescribe when a fixed ladder must be used versus a
portable ladder. However, fixed ladders are typically used to access mezzanines, the
tops of tanks, etc. Also, there are limitations to portable ladders and factors to consider
when making such a decision, including the length of the climb, how often the climb
must be made, etc.
How far must a fixed ladder extend above a landing platform?

OSHA requires under 1910.27(d)(3), “Ladder Extensions,” that the side rails of through
or side-step ladder extensions extend 31⁄2 feet above parapets and landings. OSHA
provides Figure D-10 in the standard to be used as guidance. If the fixed ladder has a
cage, then the cage must extend a minimum of 42 inches above the top of the landing,
unless other acceptable protection is provided per 1910.27(d)(1)(iii).
What must the depth be of fixed ladder steps?

The fixed ladder standard does not address the depth of ladder steps; however, OSHA
provides in 1910.27 several fixed ladder diagrams for reference to which employers
should refer for specific design suggestions. Specifically, Figure D-1 shows a minimum
3/14 Fixed Ladders–1

7 inches from the rung to the wall as a suggested ‘depth’ of ladder steps. OSHA
addresses the ‘extension of ladder rungs’ in 1910.27(d)(3), and provides Figure D-10
as a visual aid.
Fall Protection
Is fall protection required when a fixed ladder is not equipped with a cage?
As with portable ladders, OSHA does not require personal fall protection be used on
fixed ladders less than 20 feet in height. However, employers should assess the situ-
ation and provide fall protection if a fall hazard is present. For example, if the ladder is
located outside and subject to environmental conditions (e.g., ice and snow) which may
make it unsafe for climbing, additional fall protection may be warranted.
Must the entrance at the top of a fixed ladder be guarded?

Yes. The entrance at the top a fixed ladder needs to be guarded with a swinging gate
or offset passage. This is specified under 1910.23(a)(2) which states that every
ladderway floor opening or platform be guarded “with the passage through the railing
either provided with a swinging gate or so offset that a person cannot walk directly into
the opening.” This issue was addressed in a September 29, 2009 Letter of Interpreta-
tion (LOI), “Guarding of Access Openings to Fixed Ladders.” The LOI simply clarified
the existing requirements of the standard with specific regard to fixed ladders.
Inspection
Are inspections required for fixed ladders?

Yes. Fixed ladders must be inspected. OSHA requires at 1910.27(f) that fixed ladders
“be inspected regularly, with the intervals between inspections being determined by
use and exposure.” [bold emphasis added] The frequency of inspections must be done
as often as necessary to ensure the ladder is maintained in a safe condition for use.
2–Fixed Ladders 3/14

Platforms
Are platforms required on fixed ladders at a certain height?

Fixed ladder platform requirements are outlined at 1910.27(d)(2). Specifically, OSHA
requires that platforms be provided for each 30 feet of height if the ladder has a cage.
However, if the fixed ladder does not have a cage, then a platform must be provided
every 20 feet. OSHA requires a fixed ladder platform be at least 24 inches wide and 30
inches long.
What fall protection is required for fixed ladder platforms?

Fixed ladder platforms must have a standard railing and toeboard, “so arranged as to
give safe access to the ladder,” per 1910.27(d)(2)(ii).
Retrofitting
Are there any exemptions for fixed ladders installed or built prior to the standard?
OSHA addresses this issue in a May 27, 2004 LOI in which the agency says, “The
1910.27 standard which was promulgated in 1971 does not have “grandfather” provi-
sions that would allow the fixed ladders built prior to the publication of the standard to
be exempt from 1910.27 requirements. Therefore, ladders and associated safety cages
(built and installed prior to the publication of the OSHA 1910.27 standard) which do not
meet 1910.27 requirements must be retrofitted to meet 1910.27 requirements, if they
are used by the employees of the workplace.”
3/14 Fixed Ladders–3

Reserved
4–Fixed Ladders 3/14

Flammable Liquids
Bonding and Grounding
What are the requirements for grounding when transferring flammable liquids
between containers?
OSHA says at 1910.106(e)(6)(ii) that grounding must take place when dispensing into
containers for Category 1 or 2 flammable liquids, or Category 3 flammable liquids with
a flashpoint below 100°F (37.8°C) unless the nozzle and container are electrically
interconnected. If the metallic floorplate on which the container stands while filling is
electrically connected to the fill stem or if the fill stem is bonded to the container during
filling operations by means of a bond wire, then the transfer is considered grounded.
What is the requirement to bond containers when dispensing flammable liquids?

Both containers must be physically interconnected to eliminate any static electricity
which may cause a spark and ignite the flammable liquid vapors. Physically connecting
the containers equalizes the difference in the static charge which may be present
between the two object. Therefore, a ’bond’ wire between containers during flammable
liquid filling operations must be provided, unless a metallic path between them is
already present.
Although bonding will eliminate a difference in static potential between objects, it will
not eliminate a difference in potential between these objects and the earth unless one
of the containers is grounded.
How must plastic containers be interconnected?

OSHA says in a October 6, 1986 Letter of Interpretation that the safe transfer of
flammable liquids from one plastic drum or container to another may be done as
follows:
• The drum is equipped with an approved metallic suction pump and draw tube
for taking liquid through the top of the drum and the pump is electrically
grounded, or
• The drum or container is provided with a metallic self closing faucet which is
electrically grounded.
3/13 Flammable Liquids–1

Cabinets
How many flammable storage cabinets are permitted in a facility?

OSHA allows up to three flammable storage cabinets, each holding up to 60 gallons, in
any one “fire area” in a facility. A “fire area” is a section of a facility separated from other
sections by fire-resistant walls and has fire-resistant doors at each opening.
OSHA expects that all flammable liquids as defined in 1910.106(a)(19) be kept in a
flammable storage cabinet, inside storage room, or flammable storage warehouse per
1910.106(d). However, there is an exemption under 1910.106(e)(2)(i) for incidental
storage which allows employers to store up to 25 gallons of Category 1 and 120 gallons
of Categories 2, 3, and 4 in containers in any one “fire area” of the facility outside a
flammable storage cabinet or storage room.
Also, local or state fire code may dictate storage requirements; therefore, contact local
fire authorities as they generally know what OSHA requires as well as local and state
fire code and will be the best source of information regarding storage.
Also, an employer’s liability insurance carrier may require or restrict the storage of
flammable materials, which may affect insurance rates.
Do flammable storage cabinets need to be grounded?

At 1910.106(e)(6)(ii), OSHA says only that “Class I liquids shall not be dispensed into
containers unless the nozzle and container are electrically interconnected.” As such,
flammable liquid storage cabinets do not need to be grounded under the OSHA stan-
dard. However, published materials from OSHA’s Hazardous Materials course (Course
201), indicate that the requirement to ground flammable storage cabinets is found in
NFPA 77, “Recommended Practice on Static Electricity.” If NFPA 77 has been adopted
as by an employer’s state or local fire code, then compliance with this grounding
requirement would be necessary.
Can flammable and corrosive chemicals be stored in the same storage cabinet?
Yes, assuming that the chemicals are being stored in accordance with the manufac-
turers’ requirements, in approved containers, and inside an approved storage cabinet.
You should refer to the chemical’s Safety Data Sheet (SDS) for specific storage require-
ments.
Can materials be stored on top of flammable storage cabinets?

2–Flammable Liquids 3/13

of Categories 2, 3, and 4 in containers in any one “fire area” of the facility outside a
flammable storage cabinet or storage room. However, it is always a best practice to do
so.
Other types of materials stored around and/or on top of the cabinets must adhere to
general housekeeping requirements under 1910.22(a), and 1910.106(e)(9) which will
tend to control leakage and prevent the accidental escape of flammable liquids. All
spills must be cleaned up promptly.
Do storage cabinets need to be vented?

Flammable storage cabinets are not required to be vented per OSHA, nor does OSHA
expressly prohibit venting. As such, the agency refers employers to NFPA 30, “ Flam-
mable and Combustible Liquids Code.” NFPA 30 (4-3.4) states that cabinets “shall not
be required . . . to be vented for fire protection purposes and vent openings shall be
sealed. ” NFPA 30 also states “if the storage cabinet is vented for any reason, the
cabinet shall be vented direct to outdoors in such a manner that will not compromise the
specified performance of the cabinet and in a manner that is acceptable to the authority
having jurisdiction.” The “authority having jurisdiction” is typically the local Fire Marshal
or other fire authorities. As such, contact local authorities to determine if state or local
code addresses this issue.
Do flammable storage cabinets have to have self-closing doors?

At 1910.106(d)(3)(ii), OSHA prescribes the requirements for storage cabinets, whether
made of metal or wood. The regulation does not make any mention of self-closing
doors nor does the NFPA standard on flammable liquids. However, the International
Fire Code (3404.3.2.1.3, “Doors”) says of flammable storage cabinets that “Doors shall
be well fitted, self closing and equipped with a three-point latch.”
What must be done with a flammable storage cabinet that is no longer in use?
If the storage cabinet is not being used for flammable storage, the markings should be
removed. If the cabinet is also a special color which indicated that it was used for
flammable storage, consider checking with local fire authorities to see if it should be
repainted. This would prevent first responders from mistaking them for actual flam-
mable storage during an emergency. After that, an employer may do with it as they
wish.

Containers
What type of container can be used to store flammable liquids?

OSHA defines a “container” as any can, barrel, drum, or tank; however, that container
must “approved.” OSHA defines an approved container as one that is “acceptable to
the authority enforcing the code.” This would include containers allowed by the Depart-
ment of Transportation (DOT) or containers that are “listed and labeled” with an
approval from Underwriter’s Laboratory, Factory Mutual, or other Nationally Recog-
nized Testing Laboratory.
What can be used as a safety can?

OSHA says that a safety can is an approved container of five gallon capacity or less
that has a spring-closing lid and spout cover and is designed so that it will safely relieve
internal pressure when subjected to fire exposure.
Are plastic gas cans allowed?

Only plastic gas cans approved by the DOT may be used if it holds no more than 5
gallons.
Definitions
What is a flammable liquid?

OSHA defines flammable liquids at 1910.106(a)(19) as any liquid having a flashpoint at
or below 199.4°F (93°C). Flammable liquids are divided into four categories as follows:
• Category 1 includes liquids having flashpoints below 73.4°F (23°C) and hav-
ing a boiling point at or below 95°F (35°C).
• Category 2 includes liquids having flashpoints below 73.4°F (23°C) and hav-
ing a boiling point above 95°F (35°C).
• Category 3 includes liquids having flashpoints at or above 73.4°F (23°C) and
at or below 140°F (60°C). When a Category 3 liquid with a flashpoint at or
above 100°F (37.8°C) is heated for use to within 30°F (16.7°C) of its
flashpoint, it must be handled in accordance with the requirements for a
Category 3 liquid with a flashpoint below 100°F (37.8°C).
• Category 4 includes liquids having flashpoints above 140°F (60°C) and at or
below 199.4°F (93°C). When a Category 4 flammable liquid is heated for use
to within 30°F (16.7°C) of its flashpoint, it must be handled in accordance with

the requirements for a Category 3 liquid with a flashpoint at or above 100°F

(37.8°C). (v) When liquid with a flashpoint greater than 199.4°F (93°C) is
heated for use to within 30°F (16.7°C) of its flashpoint, it must be handled in
accordance with the requirements for a Category 4 flammable liquid.
What type of space can be considered a fire area?

OSHA defines a “fire area” as an area of a building separated from the remainder of the
building by construction having a fire resistance of at least one hour and having all
communicating openings properly protected by an assembly having a fire resistance
rating of at least one hour.
What is an inside storage room?

An inside storage room must be constructed to meet the required fire-resistive rating for
their use. Their construction must comply with the test specifications set forth in NFPA
251 (1969), “Standard Methods of Fire Tests of Building Construction and Materials.”
If an automatic sprinkler system is provided, it must be designed and installed in an
acceptable manner. Openings to other rooms or buildings must be provided with non-
combustible liquid-tight raised sills or ramps at least four inches in height, or the floor
in the storage area must be at least four inches below the surrounding floor. Openings
mustl be provided with approved self-closing fire doors. The room must also be liquid-
tight where the walls join the floor. A permissible alternative to the sill or ramp is an
open-grated trench inside of the room which drains to a safe location. Where other
portions of the building or other properties are exposed, windows must be protected as
set forth in NFPA 80 (1968), “Standard for Fire Doors and Windows,” which is incor-
porated by reference as specified in1910.6 for Class E or F openings.
Wood at least one inch nominal thickness may be used for shelving, racks, dunnage,
scuffboards, floor overlay, and similar installations.
What is the “flashpoint” of a liquid?

OSHA says that the “flashpoint” of a liquid the minimum temperature at which it gives
off vapor within a test vessel in sufficient concentration to form an ignitable mixture with
air near the surface of the liquid.
Gasoline
Does gasoline need to be stored inside a storage cabinet or storage room?


of Categories 2, 3, and 4 in containers in any one “fire area” of the facility outside of
flammable storage cabinet or storage room.
Storage
How much flammable liquid can be stored inside a building and not be in a flammable
storage cabinet, room, or area?
OSHA generally expects that all flammable liquids as defined at 1910.106(a)(19) will be
kept in a flammable storage cabinet, inside storage room, or flammable storage ware-
house per 1910.106(d).
There is an exemption for incidental storage at 1910.106(e)(2)(i) which allows the
storage of up to 25 gallons of Category 1 and 120 gallons of Categories 2, 3, and 4 in
containers in any one “fire area” of a facility outside a flammable storage cabinet or
storage room.
Can an outside storage shed be used to store flammable liquids?

Employers are restricted to 1,100 gallons of flammable liquid storage within 10 feet of
any buildings under 1910.106(d)(6). OSHA says that the outside storage area must be
graded in a manner to divert possible spills away from buildings or other exposures or
be surrounded by a curb at least 6 inches high. When curbs are used, employers must
make provisions for draining of accumulations of ground or rain water or spills of
flammable liquids. Drains must end at a safe location and be accessible to operation
under fire conditions.
Also, the storage area must be protected against tampering or trespassers where
necessary and be kept free of weeds, debris, and other combustible material not
necessary to the storage. Your storage must also meet any requirements of your local
and/or state fire code, so you will want to consult your local fire authorities during your
next fire inspection.

Transfer
How must large quantities of flammable liquids be transferred (e.g., from tank
trucks)?
OSHA requires at 1910.106(h)(4)(iii) that the transfer of large quantities of flammable
liquids must be through piping by means of pumps or water displacement. Gravity flow
can’t be used except as required in process equipment. The use of compressed air as
a transferring medium is prohibited.

Reserved

H
Table of Contents
Hazard Communication.......................................................................... 1
Applicability ..................................................................................... 1
Classification.................................................................................... 1
Consumer Products........................................................................... 3
Definitions ....................................................................................... 4
Inventory List ................................................................................... 5
Labeling .......................................................................................... 5
Portable Containers ......................................................................... 10
Safety Data Sheets (SDSs) ............................................................... 10
Training ......................................................................................... 16
Written Program.............................................................................. 19
9/14 H–1
Reserved
2–H 9/14
Applicability
What employers must comply with the Hazard Communication Standard?

OSHA’s Hazard Communication (HazCom) Standard applies to general industry, ship-
yard, marine terminals, longshoring, and construction employment and covers
chemical manufacturers, importers, employers, and employees exposed to chemical
hazards. Basically, any employer with one employee and one hazardous chemical is
covered.
Does the HazCom standard apply to office settings?

Office workers who encounter hazardous chemicals only in isolated instances are not
covered by the rule. OSHA considers most office products (i.e., pens, pencils, adhesive
tape) to be exempt under the provisions of the rule, either as articles or as consumer
products. For example, OSHA has previously stated that intermittent or occasional use
of a copying machine does not result in coverage under the rule. However, if an
employee handles the chemicals to service the machine, or operates it for long periods
of time, then the program would be applicable.
Classification
What is a “health” hazard?

OSHA defines a health hazard as a chemical which is classified as posing one of the
following hazardous effects:
• Acute toxicity (any route of exposure);
• Skin corrosion or irritation;
• Serious eye damage or eye irritation;
• Respiratory or skin sensitization;
• Germ cell mutagenicity;
• Carcinogenicity;
• Reproductive toxicity;
• Specific target organ toxicity (single or repeated exposure); or
9/14 Hazard Communication–1

• Aspiration hazard.
The criteria for determining whether a chemical is classified as a health hazard are
detailed in Appendix A to 1910.1200, “Health Hazard Criteria.”
What is a “physical” health hazard?

OSHA defines a physical hazard as a chemical that is classified as posing one of the
following hazardous effects:
• Explosive;
• Flammable (gases, aerosols, liquids, or solids);
• Oxidizer (liquid, solid or gas);
• Self-reactive;
• Pyrophoric (liquid or solid);
• Self-heating;
• Organic peroxide;
• corrosive to metal;
• Gas under pressure; or
• In contact with water emits flammable gas.
The criteria for determining whether a chemical is classified as a physical hazard are
detailed in Appendix B to 1910.1200, “Physical Hazard Criteria.”
How must chemical hazards be evaluated and classified?

Chemical manufacturers and importers are responsible for classifying the hazards of
the chemicals they manufacture or import. The standard provides specific criteria for
each health and physical hazard, along with detailed instructions for hazard evaluation
and determinations for classifying chemical substances and mixtures. It also estab-
lishes both hazard classes and hazard categories — for most of the effects; the classes
are divided into categories that reflect the relative severity of the effect.
Is combustible dust classified as a hazardous chemical?

In 1910.1200, OSHA defines “hazardous chemical” as “any chemical which is classified
as a physical hazard or a health hazard, a simple asphyxiant, combustible dust,
pyrophoric gas, or hazard not otherwise classified.”
OSHA specifically added the mention of simple asphyxiants, combustible dusts, and
pyrophoric gases, is that the GHS classification system does not recognize them as
hazards; however, OSHA does so they were included in the 2012 revisions to the
HazCom standard.
2–Hazard Communication 9/14

As such, chemicals which are classified as combustible dust hazards must must
include the signal word “warning” and the following hazard statement on their labels
and SDSs: “May form combustible dust concentrations in the air.”
Consumer Products
What is a “consumer product?”

The term “consumer product” means any article, or component part thereof, produced
or distributed:
• For sale to a consumer for use in or around a permanent or temporary house-
hold or residence, a school, in recreation, etc.; or
• For the personal use, consumption, or enjoyment of a consumer in or around
a permanent or temporary household or residence, a school, in recreation,
etc. (15 U.S.C.A. 2052)).
The HazCom standard specifically exempts “consumer products” from coverage.
OSHA will not issue citations for possession and/or use of consumer products unless
the compliance officer can show that the product was used in the workplace in a
manner not intended by the manufacturer or the frequency and duration of use results
in exposures that are significantly greater than those experienced by a normal con-
sumer.
In CPL 2-2.38D, “Inspection Procedures for the Hazard Communication Standard,”
OSHA instructs compliance officers to look for the following:
• What establishes the chemical as a consumer product (e.g., Was the con-
tainer label subject to the Consumer Product Safety Act provisions?)?
• What hazards does use of the product expose employees to?
• Is the product included in the employer’s hazardous chemical inventory?
• What is the duration of use of the product (e.g., For what period of time did the
employees use the chemical during the workshift and workweek? Did it greatly
exceed normal or expected use by a consumer?)?
• Was the frequency of employee use significantly greater than that of a normal
consumer?
• How was the product used and in what amounts?
• Was the product used in the workplace for the purpose intended by the manu-
facturer?
All of these questions would be considered to make sure that chemicals the employer
deems to be “consumer products” are, in fact, consumer products under the standard’s
definition.

Must SDSs be kept for consumer products?

OSHA does not require an employer to have Safety Data Sheets (SDSs) for household
consumer products (e.g., window cleaner) when the products are used in the workplace
in the same manner as a consumer would use them. In other words, when the duration
and frequency of use, and therefore exposure, is not greater than what the typical
consumer would experience. This exemption is based upon how the chemical is used
in the workplace, and also how the chemical manufacturer intended the chemical to be
used.
This exemption is based, however, not upon the chemical manufacturer’s intended use
of his product, but upon how it actually is used in the workplace. For instance, if an
employee uses kitchen cleanser to clean the sink in the breakroom twice a week, that
would be considered normal consumer exposure. However, if that employee cleans all
of the sinks in all of the building’s bathrooms everyday, that would exceed normal
consumer exposure, and the provisions of the HazCom standard would apply.
Employees who are required to work with hazardous chemicals in a manner that result
in a duration and frequency of exposure greater than what a normal consumer would
experience have a right to know about the hazards of those chemicals. In these cases,
the HazCom standard treats those consumer products as any other workplace chemi-
cal hazard.
Does the quantity of household consumer products purchased at one time matter
(e.g., purchasing a case of drain cleaner)?
Regardless of quantities, if a consumer product is used in the workplace for the pur-
pose intended by the chemical manufacturer, and the use is similar to the duration and
frequency that could reasonably be expected by consumers when used in a household,
then it falls under the consumer product exemption under the HazCom standard.
Definitions
What is a “hazardous chemical?”

OSHA defines a hazardous chemical as any chemical which is a physical hazard or a
health hazard. OSHA further defines a health hazard as a chemical for which there is
statistically significant evidence based on at least one study conducted in accordance
with established scientific principles that acute or chronic health effects may occur in
exposed employees. This includes chemicals which are carcinogens, toxic or highly
toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatoxins,
nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents
which damage the lungs, skin, eyes, or mucous membranes. This also includes chemi-
cals in all physical forms — liquids, solids, gases, vapors, fumes, and mists — whether
they are “contained” or not.

The hazardous nature of the chemical and the potential for exposure are the factors
which determine whether a chemical is covered under the HazCom standard. If it’s not
hazardous, it’s not covered. If there is no potential for exposure (e.g., the chemical is
inextricably bound and cannot be released), the rule does not cover the chemical.
Inventory List
How must a chemical inventory list be prepared?

The best and easiest way to prepare a comprehensive chemical inventory list is to
survey the entire workplace. Work systematically through the facility, and note all
chemicals in all possible forms — liquids, solids, gases, vapors, fumes, and mists.
Identify chemicals in containers, including pipes, but also chemicals generated in work
operations such as welding. Be sure to check in all cabinets, closets, and other storage
areas.
Once a workplace survey has been completed, the names of all hazardous chemicals
using the identity that is referenced on the SDS needs to be listed. This identity is often
a common name, such as the product or trade name. Note on the list the location(s) of
the products within the workplace, and an indication of the hazards as found on the
label.
When must the chemical inventory list be updated?

Update the inventory list whenever conditions in the workplace change. If a chemical
is removed from the workplace, then the employer should update the list and revise the
written HazCom program and SDS file(s) accordingly.
For the purposes of 1910.1020(d), an employer must keep a list of hazardous chemi-
cals employees may have been exposed to for the length of their employment, plus
thirty years. This list can consist of the actual SDSs or a list of departments/areas in the
workplace, what chemicals where used there, and the dates those chemicals where
used.
Labeling
Who must label hazardous chemical containers?

The manufacturer, importer, or distributor is required to label each container of haz-
ardous chemicals. If the hazardous chemicals are transferred into unmarked
containers, these containers must be labeled with the required information by the
employer, unless the container into which the chemical is transferred is intended for the
immediate use of the employee who performed the transfer.

What must a label include?

A hazardous chemical label requires the following six elements:
• Product Identifier: The name or number used for a hazardous chemical on
a label or in the SDS. It provides a unique means by which the user can
identify the chemical. The product identifier used must permit cross-
references to be made among the list of hazardous chemicals required in the
written HazCom program, the label, and the SDS.
• Pictogram: A symbol plus other graphic elements, such as a border, back-
ground pattern, or color that is intended to convey specific information about
the hazards of a chemical. Each pictogram consists of a different symbol on
a white background within a red square frame set on a point (i.e., a red
diamond).
• Signal Words: A single word used to indicate the relative level of severity of
hazard and alert the reader to a potential hazard on the label. The signal
words used are “danger” and “warning.” “Danger” is used for the more severe
hazards, while “warning” is used for less severe hazards.
• Hazard Statement: A statement assigned to a hazard class and category that
describes the nature of the hazard(s) of a chemical, including, where appro-
priate, the degree of hazard.
• Precautionary Statement: A phrase that describes recommended measures
to be taken to minimize or prevent adverse effects resulting from exposure to
a hazardous chemical, or improper storage or handling of a hazardous chemi-
cal.
• Supplier Information: Name, address, and telephone number of the chemi-
cal manufacturer, importer, or other responsible party.
Once the hazard classification is completed, the chemical’s hazard class and category
will dictate the pictogram, signal word(s), hazard statement(s), and precautionary state-
ment(s) that must be used on the label, and which must appear on the SDS.

What pictograms are required?

There are nine pictograms under the GHS to convey health, physical, and environ-
mental hazards; however, only eight pictograms are required under the HazCom
standard. The environmental pictogram is not required because these associated haz-
ards are not within OSHA’s jurisdiction. The hazard pictograms and their corresponding
hazards are shown below.
Flame Over Circle Flame Exploding Bomb

s Oxidizers s Flammables s Explosives
s Self Reactives s Self Reactives
s Pyrophorics s Organic Peroxides
s Self-Heating
s Emits Flammable Gas
s Organic Peroxides
Skull and Crossbones Corrosion Gas Cylinder
s Acute toxicity (severe) s Corrosives s Gases Under
Pressure
Health Hazard Environment Exclamation Mark

s Carcinogen s Environmental s Irritant
s Respiratory Sensitizer Toxicity s Dermal Sensitizer
s Reproductive Toxicity s Acute Toxicity
s Target Organ Toxicity (harmful)
s Mutagenicity s Narcotic Effects
s Aspiration Toxicity s Respiratory Tract
s Hazardous to Ozone
Layer
Can pictograms with black borders be used if only shipping within the United States?
All pictograms must have red borders set at a point with a black hazard symbol on a
white background, sufficiently wide to be clearly visible. . OSHA believes that the use
of the red frame will increase recognition and comprehensibility. Therefore, the red
frame is required regardless of whether the shipment is domestic or international.
Are blank red borders allowed?

All red borders printed on a label must have a symbol printed inside it. If OSHA were
to allow blank red borders, workers may be confused about what they mean and
concerned that some information is missing. OSHA has determined that prohibiting the
use of blank red borders on labels is necessary to provide the maximum recognition
and impact of warning labels and to ensure that users do not get desensitized to the
warnings placed on labels.

Can pre-printed labels with blank frames be used?

OSHA says that it is not opposed to the use of pre-printed labels; however, the HazCom
standards does not allow the use of blank red frames on labels. Blacking out the
unused frame(s) is compliant with HazCom requirements because it is not a “square
red frame set at a point without a hazard symbol.” However, if a blank red frame is not
fully covered and filled in, the label would not be in compliance.
OSHA says that adding the words “See Adjacent Pictogram(s)” within the blacked-out
area may help to reduce any potential concerns about whether a blackened frame is a
defaced label.
How must in-house containers of hazardous chemicals be labeled?

OSHA says that in-plant container labels only need the product identifier and words,
pictures, symbols, or combination thereof, which provide at least general information
regarding the hazards of the chemicals, and which, in conjunction with the other infor-
mation immediately available to employees under the hazard communication program,
will provide employees with the specific information regarding the physical and health
hazards of the hazardous chemical.
Can an employer use NFPA and HMIS labeling systems for in-house chemicals?
OSHA says that employers may choose to label workplace containers either with the
same label that would be on shipped containers for the chemical, or with label alter-
natives that meet the requirements for the standard.
Alternative labeling systems such as the National Fire Protection Association (NFPA)
704 Hazard Rating and the Hazardous Material Information System (HMIS) are per-
mitted for workplace containers. However, the information supplied on these labels
must be consistent with the HazCom standard (e.g., no conflicting hazard warnings or
pictograms.)
In short, employers may continue to use their current in-house labeling systems, but
those labels may not be used on containers leaving the workplace.
Moreover, since these alternative labels would, at a minimum, only provide the product
identifier and “general” information regarding the hazards of the chemicals, the
employer must also make “specific” information regarding the physical and health
hazards of the chemical immediately available to employees through other means.
And, employers must train employees on both the GHS-style labels and any in-house
labeling system.

How does HazCom/GHS labeling requirements differ from NFPA or HMIS labeling
systems?
HazCom/GHS uses hazard categories. NFPA and HMIS uses hazard ratings. These
systems run opposite of each other.
Under HazCom/GHS, hazard categories usually begin at “1” for the most severe and
“4” or “5” for the least severe hazards. Some hazard categories are identified by an “A”,
“B”, or other letter of the alphabet. The number identifying the hazard category will not
appear on the label — only on the SDS for the product. This is different from NFPA and
HMIS labels. The only numbers appearing on the GHS-style label will be any product
identification numbers and the phone number of the chemical manufacturer or importer.
Do HazCom pictograms and DOT placards/labels conflict with each other?

No. The Department of Transportation aligned with the GHS physical hazard criteria in
2008 in order to classify hazards for toxic materials and flammable liquids during the
transport of hazardous chemicals. The elements of the GHS which have been incor-
porated within Hazardous Materials Regulations (49 CFR Parts 100-180) have been
adopted by OSHA as well. As such, the same criteria for physical hazards is used.
Must hazardous chemicals in pipes be labeled?

Employers are not required to label pipes or piping systems.
When must label information be updated?

Chemical manufacturers, importers, distributors, or employers who become newly
aware of any significant information regarding the hazards of a chemical must revise
the labels for the chemical within six months of becoming aware of the new informa-
tion, and must ensure that labels on containers of hazardous chemicals shipped after
that time contain the new information. If the chemical is not currently produced or
imported, the chemical manufacturer, importer, distributor, or employer must add the
information to the label before the chemical is shipped or introduced into the workplace
again.
Must containers of hazardous waste intended for disposal be labeled?

No, hazardous waste is exempted from HazCom requirements because it is regulated
by the Environmental Protection Agency. Other exemptions are noted under subsection
(b) of the standard.

How must very small containers that don’t have enough space for all the required
label information be labeled when shipped?
According to 1910.1200(f)(5), each container of hazardous chemicals leaving the work-
place must be labeled, tagged, or marked in accordance with the labeling requirements
in this standard in a way that does not conflict with the requirements of the Hazardous
Materials Transportation Act and regulations issued under that Act by the Department
of Transportation (DOT).
For the containers inside that outer packaging, each must be marked with a GHS-style
label defined at 1910.1200(f)(1). Currently, OSHA does not regulate the outer shipping
container based on a September 13, 1993 Letter of Interpretation. However, employers
must follow all applicable Department of Transportation Hazardous Materials labeling
requirements.
Portable Containers
How does OSHA define “portable container”?

OSHA does not have a specific definition for portable container, but describes this type
of container in the standard as a container in which hazardous chemicals are trans-
ferred from labeled containers, and are intended only for the immediate use of the
employee who performs the transfer.
OSHA does have a definition for immediate use. Immediate use means that the haz-
ardous chemical will be under the control and used only by the person who transfers it
from a labeled container and only within the work shift in which it was transferred.
Must portable containers be labeled?

Where hazardous substances are transferred from a labeled container into a portable
container, used within a work shift, and under the control of the employee who performs
the transfer, no labels are required on the portable container.
If, however, the chemical transferred to a portable container is not used within a work
shift and under the control of the employee who performs the transfer, then labeling is
required.
How are portable containers used in-house supposed to be labeled?

If a chemical is transferred from the original container to another container(s) and will
not be used immediately by the employee who did the transfer, then the container must
be labeled. It does not, however, need the new HazCom label. An employer’s in-house
labeling system (e.g., NFPA or HMIS) is acceptable; however, the information supplied
via your in-house labeling system must be consistent with the hazards communicated
on the new HazCom label.

Safety Data Sheets (SDSs)
What chemicals need a SDS?

Employers must have a GHS-style, 16 section SDS for each chemical which is con-
sidered to be a health or physical hazard as those terms are defined in the standard,
except for those products specifically exempted under 1910.1200(b)(6).
Who must prepare and provide SDSs?

Chemical manufacturers and importers must obtain or develop a SDS for each haz-
ardous chemical they produce or import. They make the determinations as to what
chemicals are covered within the context of the standard’s requirements and develop
an appropriate SDS.
Distributors must ensure that SDSs, and updated information, are provided to other
distributors and employers with their initial shipment and with the first shipment after a
SDS is updated. The distributor must either provide SDSs with the shipped containers,
or send them to the other distributor or employer prior to or at the time of the shipment.
Retail distributors selling hazardous chemicals to employers having a commercial
account must provide a SDS to those employers upon request.
Wholesale distributors selling hazardous chemicals to employers over-the-counter may
also provide SDSs upon the request of the employer at the time of the purchase, and
must post a sign or otherwise inform the employer that a SDS is available.
Must separate SDSs be prepared for chemical mixtures?

OSHA says that where complex mixtures have similar hazards and contents (i.e., the
chemical ingredients are essentially the same but the specific composition varies from
mixture to mixture), the manufacturer, importer, or employer can prepare one SDS that
applies to all of the similar mixtures. Therefore, a single SDS can be developed for the
various combinations of chemicals, as long as the hazards of the various mixtures are
similar. This “generic” SDS must meet all of the minimum requirements found in
1910.1200(g), including the name, address, and telephone number of the responsible
party preparing or distributing the SDS who can provide additional information.

Is there a required SDS format?

Yes. OSHA requires that SDSs be in the GHS-compliant, 16-section format under
1910.1200(g). Those sections are as follows:
1. Identification
2. Hazard(s) identification
3. Composition/ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure control/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information
If no relevant information is found for one of the sections or one of the categories was
unavailable at the time of preparation, the SDS must indicate that no information was
found; blank spaces are not permitted. While OSHA cannot enforce Sections 12
through 15 of the SDS, to be GHS-compliant, the SDS must contain those sections as
well.
Does the border on the pictogram need to be red on the SDS?

No, pictograms on SDSs do not have to have red borders. OSHA provides flexibility
with regard to how pictograms are presented in Section 2 of the SDS. Appendix D of
the standard says that “Hazard symbols may be provided as graphical reproductions in
black and white or the name of the symbol (e.g., flame, skull, and crossbones).” In other
words, a pictogram with a red border, in black and white, or with no symbol at all may
be used.

Must an employer keep all SDSs sent to the company?

Employers are responsible for having SDSs for all hazardous chemicals that are in the
workplace. OSHA does not require nor encourage employers to maintain SDSs for
non-hazardous chemicals. Consequently, an employer is free to discard those for
non-hazardous chemicals, and OSHA encourages employers to use their professional
judgment in removing unnecessary SDSs from the company’s files.
What if a manufacturer does not provide an SDS?

In the event that a manufacturer or distributor does not provide an SDS with a ship-
ment, the employer should contact the supplier to obtain the necessary information.
This must be done as soon as possible. OSHA requires under 1910.1200(g)(6)(iv) that
the manufacturer or importer provide such information upon request.
Is a single SDS allowed for the same chemical from different suppliers?
According to a September 08, 2004 Letter of Interpretation, OSHA states that the
HazCom standard allows substitution of one SDS for others of similar formulations, but
the employer then assumes an increased level of responsibility.
OSHA writes “…the employer may rely on a single MSDS to convey the hazard infor-
mation for chemical products of the same formulation supplied by different
manufacturers. If the employer chooses to do this…“[the employer] must ensure that
the specific identity on the MSDS can be cross referenced to the corresponding label
of the hazardous chemical containers.
Second, the employer must ensure that employees are informed during the hazard
communication training of this practice of using one MSDS as representative of all
vendors, otherwise it could lead to confusion.
Third, the MSDS [the employer] select[s] must have complete and accurate information
as required by section (g)(3) of the HCS.
And finally, the standard requires that the MSDS contain the name, address and tele-
phone number of the party who prepares or distributes the MSDS. The party listed must
be able to provide additional information on the hazardous chemicals or clarification of
the information on the MSDS, as well as, additional emergency procedures, if neces-
sary, in lieu of the actual manufacturer. A chemical manufacturer, importer, or distributor
may not wish to and is not required to act as the responsible party for a chemical that
they did not produce.””

Must SDSs be provided in languages other than English?

OSHA requires that employers have SDSs in English. However, an employer may go
beyond this requirement and have copies of SDSs in other languages to further the
understanding of employees, and to promote general workplace safety. Also, in a Letter
of Interpretation, OSHA says “Paragraph 29 CFR 1910.1200(h) requires employers to
provide employees with information and training on hazardous chemicals in their work
area. If the employees that are required to receive this information and training does not
comprehend verbal English, the employer must inform and train these employees in a
language which is comprehensible in order to satisfy the requirements of 29 CFR
1910.1200(h).”
How do employers know if an SDS is current?

OSHA states in 1910.1200(g)(2)(xvi) that Section 16 of the SDS, “Other Information,”
should include the “date of preparation or last revision.” Also, 1910.1200(g)(5) requires
that the chemical manufacturer, importer, or employer preparing the SDS must ensure
that the information provided accurately reflects the scientific evidence used in making
the hazard classification. If the chemical manufacturer, importer, or employer preparing
the SDS becomes newly aware of any significant information regarding the hazards of
a chemical, or ways to protect against the hazards, this new information must be added
to the SDS within three months.
If the chemical is not currently being produced or imported, the chemical manufacturer
or importer must add the information to the SDS before the chemical is introduced into
the workplace again. If no new information is available, then the original SDS is suffi-
cient.
Must SDSs be made available in every department?

The requirement at 1910.1200(g)(8) says “The employer shall maintain in the work-
place copies of the required safety data sheets for each hazardous chemical, and shall
ensure that they are readily accessible during each work shift to employees when they
are in their work area(s). (Electronic access and other alternatives to maintaining paper
copies of the safety data sheets are permitted as long as no barriers to immediate
employee access in each workplace are created by such options.)”
How must SDSs be kept in the workplace?

Employers must ensure that SDSs are “readily accessible” to employees for all haz-
ardous chemicals in their workplace. This may be done in many ways. For example,
employers may keep the SDSs in a binder or on computers as long as the employees
have immediate access to the information without leaving their work area when needed
and a back-up is available for rapid access to the SDS in the case of a power outage
or other emergency.

Can SDSs be maintained on a computer?

If an employee’s work area includes the location where the SDSs can be obtained, then
maintaining SDSs on a computer would be in compliance with the requirements of the
HazCom standard. However, if the SDSs can only be accessed outside the employee’s
work area(s), then the employer would not be in compliance with 1910.1200(g)(8) or
(9). Employers must ensure that SDSs are “readily accessible” to employees for all
hazardous chemicals in their workplace.
May manufacturers supply SDSs via fax-on-demand as an alternative to paper or

other SDS formats?
In order to meet the requirements of the HazCom standard using a fax-on-demand
system, the manufacturer, distributor, or importer of the hazardous chemical (supplier)
must take some positive action to ensure that the downstream users are willing and
able to receive the information electronically. This could consist of querying the cus-
tomer and recording the response. If the customer does not wish to receive the
information via a toll-free number, a hard copy of the SDS would have to be provided.
Also, the supplier must take positive action to ensure that the customer knows how to
obtain the hazard information. OSHA would not consider an advertisement in catalogs
or other general mail communications adequate for this purpose. However, a specific
letter to the customer with detailed information would suffice.
Other criteria the supplier must fulfill are:
• In the event of a system failure, a back-up system must be available. For
instance, if the power fails and the facsimile machine is inoperable, the down-
stream user must have another means of receiving the required information
immediately. (In this case, telephone transmittal of hazard information would
be allowed as long as the SDS is delivered to the site as soon as possible.)
• In the event of a significant change to the health hazard information on the
SDS, the supplier is responsible for ensuring that the downstream users are
aware that the updated SDS is available. Some positive means of contact,
such as a letter or e-mail notification, stating that the SDS has been changed
and the updated version is available would be required.
• The employer must be made aware that the onus is upon them to ensure that
their employees are adequately trained in the system of electronic access and
know how to obtain the SDSs.

May manufacturers supply SDSs via the Internet as an alternative to paper or other
SDS formats?
Some manufacturers may consider SDS information to be proprietary, and would not
want to post this information for public access. Other manufacturers, however, have
taken advantage of the Internet and use this as a vehicle for the downstream flow of
hazard information. OSHA suggests that manufacturers who use the Internet to supply
SDSs to downstream users do the following:
• Document that customers have access to the Internet and are willing to
retrieve SDSs from this source.
• Provide these customers with a letter giving them the Internet address of all
SDSs.
• Ensure that the most current SDS is always available on the Internet. In the
event of a significant change in health hazard information, some positive
means of contact, such as a letter or e-mail notification, stating that the SDS
has changed and the updated version is available would be required.
• In the event of system failure or on-line access delays, a reliable back-up for
quickly receiving the required information must be available.
If an electronic system is used to maintain SDSs, what is acceptable in the event of

emergencies and power outages?
In the event of a power outage, equipment failure, or other “emergency” involving a
foreseeable failure of the primary electronic system, OSHA would consider telephone
transmittal of hazard information to be an adequate back-up as long as the SDS is
delivered to the site as soon as possible. An auxiliary power system would also be
acceptable to ensure that SDSs are retrievable in the situation of a general power
failure. In emergencies other than failure of the primary electronic system, the SDSs
must be available and OSHA would consider telephone transmittal of hazard informa-
tion supplemental to the data sheets.
How long must SDSs be kept after a chemical is no longer used?

Once employees have no exposure to the chemical, there is no need to keep the SDS.
However, if an employer is using SDSs to comply with 1910.1020, “ Access to
Employee Exposure and Medical Records,” then they need to be kept for the life of the
exposed employee’s employment, plus thirty years, according to the exposure records
requirements under 1910.1020(d)(1)(ii).
Be aware that employers are not required to keep SDSs as their exposure records, nor
are required to keep their chemical inventory lists. Employers ARE required to keep a
record of what chemical was used, when it was used, and where in the facility it was
used.

Training
How often must HazCom training be conducted?

OSHA says that employers must provide employees with effective information and
training on hazardous chemicals in their work area at the time of their initial assignment,
and whenever a new physical or health hazard the employees have not previously
been trained about is introduced into their work area. The intent of this requirement
outlined in 1910.1200(h)) is to have information prior to exposure to prevent the occur-
rence of adverse health effects. This purpose cannot be met if training is delayed until
a later date.
What must be included in HazCom training?

The training requirements of the standard are not satisfied solely by giving employees
the SDSs to read. Workers using hazardous chemicals will only be protected when
workers understand the information presented and are aware of the actions to be taken
to avoid or minimize exposure. Therefore, an employer’s training program is a forum for
explaining to employees not only the hazards of the chemicals in their work area, but
also how to use the information outlined in the employer’s hazard communication
program.
Specifically, OSHA says that training must include at least:
• Methods and observations that may be used to detect the presence or release
of a hazardous chemical in the work area (e.g., monitoring conducted by the
employer, continuous monitoring devices, visual appearance or odor of haz-
ardous chemicals when being released, etc.);
• The physical and health hazards of the chemicals in the work area;
• The measures employees can take to protect themselves from these hazards,
including specific procedures the employer has implemented to protect
employees from exposure to hazardous chemicals (e.g., appropriate work
practices, emergency procedures, and personal protective equipment to be
used); and
• The details of the hazard communication program developed by the employer,
including an explanation of the labeling system and SDSs, how to obtain and
use the appropriate hazard information, the location and availability of the
written HazCom program, etc.
Training on SDSs must include an explanation of each of the 16 sections and the
information that can be found in each section, and why that information is important to
the user.
Training need not be conducted on each specific chemical found in the workplace, but
may be conducted by categories of hazard (e.g., carcinogens, sensitizers, acutely toxic
agents) that are or may be encountered by an employee during the course of his or her
duties.

Furthermore, the training must be comprehensible. Employers should consider the

education and technical background of the employees to ensure that they completely
understand the information being given to them. If employees receive job instructions
in a language other than English, then the training and information to be conveyed
under the standard will also need to be conducted in that same language.
How will OSHA determine if an employer’s HazCom training is effective?

OSHA compliance officers will usually talk to employees to determine if they have
received training, if they know they are exposed to hazardous chemicals, and if they
know where to obtain substance-specific information on labels and SDSs.
OSHA says that they do not expect that every worker will be able to recite all the
information about each chemical in the workplace or recall all the information that was
provided in training. OSHA does expect that employees would know that they are
exposed to hazardous chemicals, that they know how to read and use labels and
SDSs, and that, as a consequence of learning this information, they are following the
appropriate protective measures established by the employer.
If the compliance officers detects a trend in employee responses that indicates training
is not being conducted, or is conducted in a cursory fashion that does not meet the
intent of the standard, he or she will take a closer look at the written program and how
it is implemented. The written program should provide enough details about the
employer’s HazCom training so that a compliance officer can assess whether or not a
good faith effort is being made to train employees.
The rule does not require employers to maintain records of employee training, but
many employers choose to do so to ensure that they have trained all employees
appropriately.
What are the requirements for refresher training?

Additional training is to be done whenever a new physical or health hazard is intro-
duced into the work area, not a new chemical. For example, if a new solvent is brought
into the workplace, and it has hazards similar to existing chemicals for which training
has already been conducted, then no new training is required. As with initial training,
and in keeping with the intent of the standard, the employer must make employees
specifically aware which hazard category (i.e., corrosive, irritant, etc.) the solvent falls
within. The substance-specific data sheet must still be available, and the product must
be properly labeled. If the newly introduced solvent is a suspect carcinogen, and there
has never been a carcinogenic hazard in the workplace before, then new training for
carcinogenic hazards must be conducted for employees in those work areas where
employees will be exposed.

Must employers retrain new hires if they have already received HazCom training?
It is not necessary that an employer retrain each new hire if that employee has received
prior training by a past employer, an employee union, or any other entity. General
information, such as the rudiments of the HazCom standard could be expected to
remain with an employee from one position to another. The employer, however, main-
tains the responsibility to ensure that their employees are adequately trained and are
equipped with the knowledge and information necessary to conduct their jobs safely.
As such, it is likely that additional training will be needed since employees must know
the specifics of their new employers’ programs such as where the SDSs are located,
details of the employer’s in-plant labeling system if it is different than that required by
the standard, and the hazards of new chemicals to which they will be exposed. For
example, 1910.1200(h)(3)(iii) requires that employees be trained on the measures they
can take to protect themselves from hazards, including specific procedures the
employer has implemented such as work practices, emergency procedures, and per-
sonal protective equipment to be used. An employer, therefore, has a responsibility to
evaluate an employee’s level of knowledge with regard to the hazards in the workplace,
their familiarity with the requirements of the standard, and the employer’s hazard com-
munication program.
Who must train contract employees or temporary workers?

The contractor and/or the temporary agency employer would be expected to provide
general hazard training and information concerning categories of chemicals employees
may encounter. Host employers would then be responsible for providing site-specific
hazard training as required by the standard.
Do employees who do not handle or have contact with chemicals need to be trained?
For locations “where employees only handle chemicals in sealed containers which are
not opened under normal conditions of use (such as are found in marine cargo han-
dling, warehousing, or retail sales)” OSHA states at 1910.1200(b)(4) that employers
must:
• Ensure that labels on incoming containers of hazardous chemicals are not
removed or defaced;
• Maintain copies of any safety data sheets that are received with incoming
shipments of the sealed containers of hazardous chemicals, must obtain a
SDS as soon as possible for sealed containers of hazardous chemicals
received without a safety data sheet if an employee requests the safety data
sheet, and must ensure that the safety data sheets are readily accessible
during each work shift to employees when they are in their work area(s); and

• Ensure that employees are provided with information and training in accor-
dance with paragraph (h) of this standard (except for the location and
availability of the written hazard communication program under paragraph
(h)(2)(iii)), to the extent necessary to protect them in the event of a spill or leak
of a hazardous chemical from a sealed container.
Must training be documented?

OSHA does not require HazCom training documentation or certification.
Written Program
Why is a written HazCom program necessary?

A written HazCom program helps employers to inform and train their employees prop-
erly and to design and put in place employee protection programs. It also provides
necessary hazard information to employees so that they can participate in, and sup-
port, the protective measures in place at their workplaces.
The written HazCom program must include information on container labeling, collection
and availability of SDSs, and the employee training program. It also must contain a list
of the hazardous chemicals, the means the employer will use to inform employees of
the hazards of non-routine tasks (e.g., the cleaning of reactor vessels), and the hazards
associated with chemicals in unlabeled pipes.

I/J/K
Table of Contents
Injury and Illness Recordkeeping ............................................................ 1

Annual Summary .............................................................................. 1
Contract or Temporary Employees ....................................................... 3
Days Away ...................................................................................... 3
Exceptions....................................................................................... 6
First Aid .......................................................................................... 8
Forms ........................................................................................... 10
Job Transfer ................................................................................... 10
Medical Treatment ........................................................................... 11
New Cases .................................................................................... 12
Parking Lots ................................................................................... 13
Postings ........................................................................................ 14
Recording Criteria ........................................................................... 14
Recordkeeping ............................................................................... 15
Reporting....................................................................................... 16
Restricted Work .............................................................................. 16
Work-Relatedness ........................................................................... 19
Inspections........................................................................................... 1
Checklists........................................................................................ 1
Corrective Actions ............................................................................. 1
Equipment ....................................................................................... 2
Frequency ....................................................................................... 2
Personnel ........................................................................................ 3
Recordkeeping ................................................................................. 3
Required Inspections ......................................................................... 4
Training ......................................................................................... 60
9/12 I/J/K–1
Reserved
2–I/J/K 9/12
Annual Summary
How must the annual summary be completed?

Employers must:
• Total the columns on the OSHA 300 Log (if there were no recordable cases,
enter zeros for each column total); and
• Enter the calendar year covered, the company’s name, establishment name,
establishment address, annual average number of employees covered by the
OSHA 300 Log, and the total hours worked by all employees covered by the
OSHA 300 Log.
If using an equivalent form other than the OSHA 300A Summary form, the summary
used must also include the employee access and employer penalty statements found
on the OSHA 300A Summary form.
How are the “total hours worked” calculated when there are both hourly and tempo-
rary workers?
To calculate the total hours worked by all employees, include the hours worked by
salaried, hourly, part-time and seasonal workers, as well as hours worked by other
workers supervised (e.g., workers supplied by a temporary help service). Do not
include vacation, sick leave, holidays, or any other non-work time even if employees
were paid for it. If the establishment keeps records of only the hours paid or if the
employer has employees who are not paid by the hour, the hours that the employees
actually worked must be estimated.
How is the “average number of employees” calculated?

The formula is: Number of employees paid in all pay periods ÷ Number of pay periods
= Average number of employees. For example, a company has 150 employees and
pays them twice a month (on the 1st and the 15th). This means the company has 24
“pay periods” each year. In this example, a total of 3600 employees were paid in all pay
periods. It may help to think of this total as the number of paychecks issued throughout
the year. This total is then divided by the number of pay periods (3600 ÷ 24) which gives
an annual average of 150 employees.
A common mistake in this case would be to list 150 employees on OSHA’s worksheet
and divide by 24 pay periods. This gives an average of only about six employees. The
error is failing to add up the total number of employees paid in all pay periods.
Injury and Illness Recordkeeping–1

This calculation is important when the number of workers changes from month to
month. Some companies increase their workforce during the summer, or use a tem-
porary workers to meet production demands, and need to calculate their average for
the year.
How must the annual summary be certified?

A company executive must certify that he or she has examined the OSHA 300 Log and
that he or she reasonably believes, based on his or her knowledge of the process by
which the information was recorded, that the annual summary is correct and complete.
Who is considered a company executive?

The company executive who certifies the log must be one of the following persons:
• An owner of the company (only if the company is a sole proprietorship or
partnership);
• An officer of the corporation;
• The highest ranking company official working at the establishment; or
• The immediate supervisor of the highest ranking company official working at
the establishment.
If there are no recordable cases for the year is an annual summary still required to be
completed, certified, and posted?
Yes. After the end of the year, employers must review the Log to verify its accuracy,
summarize the 300 Log information on the 300A Summary form, and certify the sum-
mary. This information must then be posted for three months, from February 1 to April
30.
May several 300 Logs be combined in one annual summary?

No. Each establishment with its own 300 Log must have its own summary. The sum-
mary gives workers information about the number and type of injuries where they work,
not the numbers for the whole company. However, the rule does an employer to
combine short-term work locations (in operation for less than one year) on one 300 Log.
If several short-term establishments are included on one log, the employer may pre-
pare one summary from that log.
2–Injury and Illness Recordkeeping

Contract or Temporary Employees
Must an employer record an injury or illness occurring to a contract employee?

If the contractor’s employee is under the day-to-day supervision of the contractor, the
contractor is responsible for recording the injury or illness. The employer must record
the injury or illness if they supervise the contractor employee’s work on a day-to-day
basis.
How are injuries or illnesses to employees from a temporary help service recorded?
The employer who supervises the temporary employees on a day-to-day basis must
record the case. The employer and the temporary help service should coordinate
efforts to make sure that each injury and illness is recorded only once: either on on the
employer’s OSHA 300 Log (if day-to-day supervision is provided) or on the other
employer’s OSHA 300 Log (if that company provides day-to-day supervision).
How is “day-to-day supervision” defined?

The host employer must record the recordable injuries and illnesses of employees not
on its payroll if it supervises them on a day-to-day basis. Day-to-day supervision occurs
when “in addition to specifying the output, product or result to be accomplished by the
person’s work, the employer supervises the details, means, methods, and processes
by which the work is to be accomplished.”
Days Away
How is a work-related injury or illness that results in days away from work recorded?
When an injury or illness involves one or more days away from work, the employer
must record the injury or illness on the OSHA 300 Log with a check mark in the space
for cases involving days away and an entry of the number of calendar days away from
work in the number of days column. If the employee is out for an extended period of
time, the employer must enter an estimate of the days that the employee will be away,
and update the day count when the actual number of days is known.
When does the day count begin?

Begin counting days away on the day after the injury occurred or the illness began.

Is there a limit to the number of days away from work that must be counted?
Yes, the total days away may be “capped” at 180 calendar days. An employer is not
required to keep track of the number of calendar days away from work if the injury or
illness resulted in more than 180 calendar days away from work and/or days of job
transfer or restriction. In such a case, entering 180 in the total days away column is
considered adequate.
May the day count stop if an employee who is away from work because of an injury
or illness retires or leaves my company?
Yes, if the employee leaves the company for some reason unrelated to the injury or
illness (e.g., retirement, plant closing, another job), the employer may stop counting
days away from work or days of restriction/job transfer. If the employee leaves the
company because of the injury or illness, the total number of days away or days of
restriction/job transfer must be estimated and the day count entered on the 300 Log.
If a case occurs in one year but results in days away during the next calendar year,
is the case recorded in both years?
No, the injury or illness is only recorded once. The employer must enter the number of
calendar days away for the injury or illness on the OSHA 300 Log for the year in which
the injury or illness occurred. If the employee is still away from work because of the
injury or illness when the annual summary is prepared, estimate the total number of
calendar days the employee is expected to be away from work. Use this number to
calculate the total for the annual summary, and then update the initial log entry later
when the day count is known or reaches the 180-day cap.
How is an injury or illness recorded when a physician or other licensed health care
professional recommends that the worker stay at home but the employee comes to
work anyway?
The employer must record these injuries and illnesses on the OSHA 300 Log using the
check box for cases with days away from work and enter the number of calendar days
away recommended by the physician or other licensed health care professional. If a
physician or other licensed health care professional recommends days away, you
should encourage your employee to follow that recommendation.
However, the days away must be recorded whether the injured or ill employee follows
the physician or licensed health care professional’s recommendation or not. If the
employer receives recommendations from two or more physicians or other licensed
health care professionals, they may make a decision as to which recommendation is
the most authoritative, and record the case based upon that recommendation.

How is a case handled when a physician or other licensed health care professional
recommends that the worker return to work but the employee stays at home anyway?
In this situation, the employer must end the count of days away from work on the date
the physician or other licensed health care professional recommends that the
employee return to work.
How are weekends, holidays, or other days the employee would not have worked
anyway counted?
The employer must count the number of calendar days the employee was unable to
work as a result of the injury or illness, regardless of whether or not the employee was
scheduled to work on those day(s). Weekend days, holidays, vacation days, or other
days off are included in the total number of days recorded if the employee would not
have been able to work on those days because of a work–related injury or illness.
How is a case recorded in which a worker is injured or becomes ill on a Friday and
reports to work on a Monday, and was not scheduled to work on the weekend?
The employer needs to record this case only if information is received from a physician
or other licensed health care professional indicating that the employee should not have
worked, or should have performed only restricted work, during the weekend. If so, the
employer must record the injury or illness as a case with days away from work or
restricted work, and enter the day counts, as appropriate.
If an employee who sustains a work-related injury requiring days away from work is
terminated for drug use based on the results of a post-accident drug test, how is the
case recorded?
Under section 1904.7(b)(3)(vii), the employer may stop counting days away from work
if an employee who is away because of an injury or illness leaves the company for
some reason unrelated to the injury or illness, such as retirement or a plant closing.
However, when the employer conducts a drug test based on the occurrence of an
accident resulting in an injury at work and subsequently terminates the injured
employee, the termination is related to the injury. Therefore, the employer must esti-
mate the number of days that the employee would have been away from work due to
the injury and enter that number on the 300 Log.
If an employee leaves the company after experiencing a work-related injury or illness

that results in days away from work and/or days of restricted work/job transfer how
would an employer record the case?
If the employee leaves the company for some reason(s) unrelated to the injury or
illness, the employer may stop counting days away from work or days of restriction/job
transfer. In order to stop a count there must first be a count to stop. Thus, the employer
must count at least one day away from work or day of restriction/job transfer on the

OSHA 300 Log. If the employee leaves the company for some reason(s) related to the
injury or illness, the employer must make an estimate of the count of days away from
work or days of restriction/job transfer expected for the particular type of case.
Exceptions
What injuries and illness aren’t recordable?

Any illness or injury that happens in the work environment is assumed to be work-
related unless one of the exceptions applies. These are specifically listed in
1904.5(b)(2). An employer is not required to record an injury or illness if one of the
following nine exceptions is met:
1. Member of the general public – If, at the time of the injury or illness, the employee
was present as a member of the general public rather than as an employee, it is not
recordable. For example, an employee of a hardware store is injured while shopping in
the store on his day off.
2. Symptoms surface at work – If the injury or illness involves signs or symptoms that
surface at work, but is caused solely from a non-work related event or exposure, it is
not recordable. For example, an employee has an epileptic seizure and breaks an arm
during convulsions. The injury was caused solely by the seizure. Epilepsy is a non–
occupational condition, so the resulting injury is not work–related.
3. Voluntary participation in wellness programs or recreational activities – If the
injury or illness results solely from voluntary participation in a wellness program or in a
medical, fitness, or recreational activity (e.g., blood donation, physical examination, flu
shot, exercise class, baseball) it is not recordable. For example, an employee passes
out while giving blood during a company–sponsored (but voluntary) blood drive.
4. Eating, drinking, or preparing food – If the injury or illness is solely the result of an
employee eating, drinking, or preparing food or drink for personal consumption,
whether bought on the employer’s premises or brought in, it is not recordable. For
example, an employee chokes on a sandwich brought from home or bought in the
cafeteria.
However, this exception does not apply to food provided by the employer for company
functions. If an employee gets food poisoning from meal provided by the employer at
a business meeting, it is work–related.
Also, it is important to note that this exception applies only to injuries or illnesses that
result from food or food preparation. Other injuries that occur in a lunchroom or caf-
eteria (e.g., slips or falls) are not covered by the exception and may result in a
recordable case.

5. Personal tasks – Injuries or illnesses are not recordable if they happen when an
employee is doing personal tasks that are unrelated to their job and the activity is
outside of assigned working hours. For example, an employee comes in after work and
uses a conference room to work on a child’s science project.
OSHA has ruled that breaks (e.g., lunch breaks) are within assigned working hours. As
such, an employee who falls down and gets hurt during a smoking break is not exempt
because the break was within assigned working hours. Also, an employee who stays
after hours to finish a project is not performing a personal task, and any injury would be
work-related. To be exempt, both conditions must be in place.
6. Personal grooming – An injury or illness is not recordable if it is solely the result of
personal grooming, self medication for a non–work–related condition, or is intentionally
self–inflicted. For example, an employee has an allergic reaction to a personal medi-
cation.
However, if an employee falls and is injured while showering to remove a contaminant
that he was exposed to on the job, it would be a recordable incident.
And although drug and alcohol use fall under this exception, an injury must be solely
the result of drug or alcohol use to not be recordable. If a post-accident drug test is
positive, it is reasonable to think that impaired judgment lead to the accident. However,
the accident may not have been solely caused by the drug as other workplace factors
may have contributed.
7. Vehicle accidents – If the injury or illness is caused by a vehicle accident in a
company parking lot or company access road while the employee is commuting to or
from work, it is not recordable.
Other injuries in the parking lot or access road are work-related and potentially record-
able. Company parking lots are part of the work environment because the employee is
present as a condition of employment. If an employee is injured by slipping on ice or
tripping in a pothole while walking from car to building, it would be recordable.
However, if an employee is struck by a car in the company parking lot, the injury is not
recordable because the employer has no control over the driver of the vehicle. The
same is true for injuries that occur in public parking lots or on public streets. They are
not recordable because the employer has no control over conditions in these areas –
they are not part of the employers “work environment.”
8. Common cold and flu – The common cold or flu is not recordable, even if the
illnesses are contracted at work. However, other infectious diseases like tuberculosis,
brucellosis, or hepatitis A must be evaluated for work relationships. If an employee is
infected at work through exposure to another worker’s blood, then the case is record-
able.
9. Mental illness – Mental illness is not recordable unless the employee voluntarily
provides an opinion from a physician or licensed health care professional (e.g., psy-
chiatrist, psychologist) stating that the employee has a mental illness that is work–
related. For example, an employee who witnesses a serious accident is traumatized
and requires time away from work.

What are considered “personal grooming” activities?

Personal grooming activities are those directly related to personal hygiene (e.g., comb-
ing and drying hair, brushing teeth, clipping fingernails). Bathing or showering at the
workplace when necessary because of an exposure to a substance at work is not within
the personal grooming exception in 1904.5(b)(2)(vi). Thus, if an employee slips and
falls while showering at work to remove a contaminant to which he has been exposed
at work, and sustains an injury that meets one of the general recording criteria listed in
1904.7(b)(1), the case is recordable.
What are considered “personal tasks?”

“Personal tasks” are those that are unrelated to the employee’s job. For example, if an
employee uses a company break area to work on his child’s science project, he is
engaged in a personal task.
First Aid
What is “first aid?”

For recordkeeping purposes, “first aid” means the following:
• Using a non-prescription medication at nonprescription strength (for medica-
tions available in both prescription and non-prescription form, a
recommendation by a physician or other licensed health care professional to
use a non-prescription medication at prescription strength is considered medi-
cal treatment for recordkeeping purposes);
• Administering tetanus immunizations (the Hepatitis B or rabies vaccine are
considered medical treatment);
• Cleaning, flushing, or soaking wounds on the surface of the skin;
• Using wound coverings (e.g., bandages, Band–Aids™, gauze pads), butterfly
bandages, or Steri–Strips™ (other wound closing devices such as sutures,
staples, etc. are considered medical treatment);
• Using hot or cold therapy;
• Using any non–rigid means of support (e.g., elastic bandages, wraps, non-
rigid back belts);
• Using temporary immobilization devices while transporting an accident victim
(e.g., splints, slings, neck collars, back boards);
• Drilling of a fingernail or toenail to relieve pressure or draining fluid from a
blister;
• Using eye patches;

• Removing foreign bodies from the eye using only irrigation or a cotton swab;
• Removing splinters or foreign material from areas other than the eye by
irrigation, tweezers, cotton swabs, or other simple means;
• Using finger guards;
• Using massages (physical therapy or chiropractic treatment are considered
medical treatment for recordkeeping purposes); or
• Drinking fluids for relief of heat stress.
This is a complete list of all treatments and no other procedures are included in first aid
for recordkeeping purposes.
Are surgical glues used to treat lacerations considered “first aid?”

Surgical glue is a wound closing device. All wound closing devices except for butterfly
and Steri–Strips™ are “medical treatment” because they are not included on the first
aid list.
What is considered to be prescription strength for medications such as Ibuprofen?

The prescription strength of such medications is determined by the measured quantity
of the theraputic agent to be taken at one time (i.e., a single dose). The single dosages
that are considered prescription strength for four common over-the-counter drugs are:
• Ibuprofen (such as Advil™) – Greater than 467 mg
• Diphenhydramine (such as Benadryl™) – Greater than 50 mg
• Naproxen Sodium (such as Aleve™) – Greater than 220 mg
• Ketoprofen (such as Orudus KT™) – Greater than 25mg
To determine the prescription-strength dosages for other drugs that are available in
prescription and non-prescription formulations, the employer should contact OSHA, the
United States Food and Drug Administration, or their local pharmacist or their physi-
cian.
What are “other simple means” of removing splinters that are considered first aid?
“Other simple means” of removing splinters would include methods that are reasonably
comparable to the methods already listed in the standard (i.e., irrigation, tweezer,
cotton swabs). Using needles, pins, or small tools to extract splinters would generally
be included.
Must inoculations be recorded?

The issue of whether or not immunizations and inoculations are first aid or medical
treatment is irrelevant for recordkeeping purposes unless a work-related injury or ill-
ness has occurred. Immunizations and inoculations that are provided for public health

or other purposes, where there is no work-related injury or illness, are not first aid or
medical treatment, and do not in themselves make the case recordable. However,
when inoculations are given in response to workplace exposure, medical treatment has
been rendered and the case must be recorded.
Forms
How must the OSHA 300 Log be completed?

Information about the business must be entered at the top of the OSHA 300 Log and
a one or two line description for each recordable injury or illness.
What must be done to complete the OSHA 301 Incident Report?

An OSHA 301 Incident Report form, or an equivalent form, must be completed for each
recordable injury or illness entered on the OSHA 300 Log.
What is an equivalent form?

An equivalent form is one that has the same information, is as readable and under-
standable, and is completed using the same instructions as the OSHA form it replaces.
Many employers use an insurance form instead of the OSHA 301 Incident Report, or
supplement an insurance form by adding any additional information required by OSHA.
When must each injury or illness be recorded?

Each recordable injury or illness must be recorded on the OSHA 300 Log and 301
Incident Report within seven calendar days of receiving information that a recordable
injury or illness has occurred.
Job Transfer
How is it decided if an injury or illness involved a transfer to another job?

If an injured or ill employee is assigned to a job other than his or her regular job for part
of the day, the case involves transfer to another job (this does not include the day on
which the injury or illness occurred).

Are transfers to another job recorded in the same way as restricted work cases?
Yes, both job transfer and restricted work cases are recorded in the same box on the
OSHA 300 Log. For example, if the employer assigns, or a physician or other licensed
health care professional recommends that the employer assigns, an injured or ill worker
to his or her routine job duties for part of the day and to another job for the rest of the
day, the injury or illness involves a job transfer. An injury or illness that involves a job
transfer must be recorded by placing a check in the box for job transfer.
How are days of job transfer or restriction counted?

Days of job transfer or restriction are counted in the same way days away from work are
counted. The only difference is that, if the employer permanently assigns the injured or
ill employee to a job that has been modified or permanently changed in a manner that
eliminates the routine functions the employee was restricted from performing, the day
count may be stopped when the modification or change is made permanent. At least
one day of restricted work or job transfer must be counted for such cases.
How long must a modification to a job last before it can be considered a permanent
modification?
A permanent restriction or transfer is one that is expected to last for the remainder of
the employee’s career. Where the restriction or transfer is determined to be permanent
at the time it is ordered, the employer must count at least one day of the restriction or
transfer on the Log. If the employee whose work is restricted or who is transferred to
another job is expected to return to his or her former job duties at a later date, the
restriction or transfer is considered temporary rather than permanent.
Medical Treatment
What is the definition of “medical treatment?”

“Medical treatment” means the management and care of a patient to combat disease
or disorder. For recordkeeping purposes, medical treatment does not include:
• Visits to a physician or other licensed health care professional solely for
observation or counseling;
• The conduct of diagnostic procedures (e.g., x-rays, blood tests), including the
administration of prescription medications used solely for diagnostic purposes
(e.g., eye drops to dilate pupils); or
• First aid.

What is a “significant” diagnosed injury or illness?

OSHA believes that cancer, chronic irreversible diseases, fractured or cracked bones,
and punctured eardrums are generally considered significant injuries and illnesses, and
must be recorded at the initial diagnosis even if medical treatment or work restrictions
are not recommended, or are postponed, in a particular case.
What if medical treatment is recommended but the employee does not follow it?
If a physician or other licensed health care professional recommends medical treat-
ment, the employer should encourage the injured or ill employee to follow that
recommendation. However, the case must be recorded even if the injured or ill
employee does not follow the recommendation.
New Cases
What is considered a new case?

An employer must consider an injury or illness to be a “new case” if:
1. The employee has not previously experienced a recorded injury or illness of
the same type that affects the same part of the body, or
2. The employee previously experienced a recorded injury or illness of the same
type that affected the same part of the body but had recovered completely (all
signs and symptoms had disappeared) from the previous injury or illness and
an event or exposure in the work environment caused the signs or symptoms
to reappear.
When an employee experiences the signs or symptoms of a chronic work-related

illness, is each recurrence of signs or symptoms a new case?
No. For occupational illnesses where the signs or symptoms may recur or continue in
the absence of an exposure in the workplace, the case must only be recorded once.
Examples may include occupational cancer, asbestosis, byssinosis and silicosis.
When an employee experiences the signs or symptoms of an injury or illness as a

result of an event or exposure in the workplace (e.g., occupational asthma) must the
episode be treated as a new case?
Yes. The incident must be treated as a new case because the episode or recurrence
was caused by an event or exposure in the workplace.

May an employer rely on a physician or other licensed health care professional to

determine whether a case is a new case or a recurrence of an old case?
An employer is not required to seek the advice of a physician or other licensed health
care professional. However, if such advice is sought, the employer must follow the
physician or other licensed health care professional’s recommendation about whether
the case is a new case or a recurrence. If recommendations from two or more physi-
cians or other licensed health care professionals are received, the employer must make
a decision as to which recommendation is the most authoritative (best documented,
best reasoned, or most authoritative), and record the case based upon that recom-
mendation.
How is an employer to determine whether an employee has “recovered completely”

from a previous injury or illness to conclude an event is a new case?
An employee has “recovered completely” from a previous injury or illness when he or
she is fully healed or cured. The employer must use their best judgment based on
factors such as the passage of time since the symptoms last occurred and the physical
appearance of the affected part of the body. If the signs and symptoms of a previous
injury disappear for a day only to reappear the following day, that is strong evidence the
injury has not properly healed.
The employer may, but is not required to, consult a physician or other licensed health
care provider (PLHCP). Where the employer does consult a PLHCP to determine
whether an employee has recovered completely from a prior injury or illness, it must
follow the PLHCP’s recommendation. In the event the employer receives recommen-
dations from two or more PLHCPs, the employer may decide which recommendation
is the most authoritative and record the case based on that recommendation.
Parking Lots
What is considered a company parking lot?

Company parking lots are part of the employer’s premises and therefore part of the
establishment. These areas are under the control of the employer and access can be
limited (e.g., a parking lot limited to the employer’s employees and visitors). On the
other hand, a parking area where the employer does not have control (e.g., a parking
lot outside of a building shared by different employers, or a public parking area like
those found at a mall or beneath a multi-employer office building) would not be con-
sidered part of the employer’s establishment (except for the owner of the building or
mall); and therefore, not a company parking lot for purposes of OSHA recordkeeping.

If an employee is walking across a parking lot when and struck by a car driven by
another employee who is coming to work and both employees are seriously injured
in the accident is either case work-related?
Neither employee’s injuries are recordable. While the employee parking lot is part of the
work environment in accordance with 1904.5, injuries occurring there are not work-
related if they meet the exception at 1904.5(b)(2)(vii). Specifically, 1904.5(b)(2)(vii)
excepts injuries caused by motor vehicle accidents occurring on the company parking
lot while the employee is commuting to and from work. In the case in question, both
employees’ injuries resulted from a motor vehicle accident in the company parking lot
while the employees were commuting. Accordingly, the exception applies.
Postings
How must the annual summary be posted?

A copy of the annual summary must be posted in each establishment in a conspicuous
place or places where notices to employees are customarily posted (e.g., a lunchroom
bulletin board). The employer must ensure that the posted annual summary is not
altered, defaced, or covered by other material.
When must the annual summary be posted?

The summary must be posted no later than February 1 of the year following the year
covered by the records and be kept in place until April 30.
Recording Criteria
What injury and illnesses are recordable?

In order to be recordable, an injury or illness must meet all of the following conditions:
1. Is work-related (1904.5);
2. Is a new case (1904.6); and
3. Results in death, loss of consciousness, days away from work, job transfer or
work restriction, medical treatment beyond first aid, or is a significant injury or
illness diagnosed by a physician or other licensed health care professional
(1904.7).

Is every work-related injury or illness case involving a loss of consciousness record-

able?
Yes, a work-related injury or illness must be recorded if the worker becomes uncon-
scious regardless of the length of time the employee remains unconscious.
If an employee reports an injury or illness must it be recorded?

In determining whether a case is recordable, the employer must first decide whether an
injury or illness, as defined by the rule, has occurred. If the employer is uncertain about
whether an injury or illness has occurred, the employer may refer the employee to a
physician or other health care professional for evaluation and may consider the health
care professional’s opinion in determining whether an injury or illness exists. If a phy-
sician or other licensed health care professional diagnoses a significant injury or illness
within the meaning of 1904.7(b)(7) and the employer determines that the case is
work-related, the case must be recorded.
Recordkeeping
Do I have to update the OSHA 300 Log during required the five-year storage period?
Yes, during the storage period, the employer must update stored OSHA 300 Logs to
include newly discovered recordable injuries or illnesses and to show any changes that
have occurred in the classification of previously recorded injuries and illnesses. If the
description or outcome of a case changes, the employer must remove or line out the
original entry and enter the new information.
How would the employer record the change on the OSHA 300 Log for an injury or
illness after the injured worker reached the cap of 180 days for restricted work and
then was assigned to “days away from work”?
The employer must check the box that reflects the most severe outcome associated
with a given injury or illness. The severity of any case decreases on the log from column
G (Death) to column J (Other recordable case). Since days away from work is a more
severe outcome than restricted work the employer is required to remove the check
initially placed in the box for job transfer or restriction and enter a check in the box for
days away from work (column H). Employers are allowed to cap the number of days
away and/or restricted work/job transfer when a case involves 180 calendar days. For
purposes of recordability, the employer would enter 180 days in the “Job transfer or
restriction” column and may also enter 1 day in the “Days away from work” column to
prevent confusion or computer related problems.

Must employees have access to OSHA injury and illness records?

Yes, employees, former employees, their personal representatives, and their autho-
rized employee representatives have the right to access the OSHA injury and illness
records. The employer must give the requester a copy of the relevant OSHA 300 Log(s)
or OSHA 301 Incident Report by the end of the next business day.
When an authorized employee representative asks for copies of the OSHA 301 Incident
Reports for an establishment where the agent represents employees under a collective
bargaining agreement, the employer must give copies of those forms to the authorized
employee representative within seven calendar days. The employer is only required to
give the authorized employee representative information from the OSHA 301 Incident
Report section titled “Tell us about the case.” All other information must be removed
from the copy of the OSHA 301 Incident Report that is given to the authorized employee
representative.
Reporting
What must an employer do to ensure employees report work-related injuries and

illnesses?
Employers are required to let employees know how and when to report work-related
injuries and illnesses. This means that the employer must set up a way for the employ-
ees to report work-related injuries and illnesses and tell its employees how to use it.
OSHA does not specify how the employer must accomplish these objectives, so
employers have flexibility to set up systems that are appropriate to their workplace.
Restricted Work
How is it decided if an injury or illness results in restricted work?

Restricted work occurs when, as the result of a work-related injury or illness:
• The employer keeps the employee from performing one or more of the routine
functions of his or her job, or from working the full workday that he or she
would otherwise have been scheduled to work; or
• A physician or other licensed health care professional recommends that the
employee not perform one or more of the routine functions of his or her job,
or not work the full workday that he or she would otherwise have been sched-
uled to work.

What is meant by “routine functions?”

For recordkeeping purposes, an employee’s routine functions are those work activities
the employee regularly performs at least once per week.
How is a work-related injury or illness that results in restricted work or job transfer
recorded?
When an injury or illness involves restricted work or job transfer but does not involve
death or days away from work, the employer must record the injury or illness on the
OSHA 300 Log by placing a check mark in the space for job transfer or restriction and
an entry of the number of restricted or transferred days in the restricted workdays
column.
Does restricted work or job transfer have to be recorded if it applies only to the day
on which the injury occurred or the illness began?
No. Restricted work or job transfers do not have to be recorded if the employer, or the
physician or other licensed health care professional, impose the restriction or transfer
only for the day on which the injury occurred or the illness began.
If a work restriction recommended, is the injury or illness automatically recordable as

a “restricted work” case?
No. A recommended work restriction is recordable only if it affects one or more of the
employee’s routine job functions. To determine whether this is the case, the employer
must evaluate the restriction in light of the routine functions of the injured or ill employ-
ee’s job. If the restriction from the employer or the physician or other licensed health
care professional keeps the employee from performing one or more of his or her routine
job functions or from working the full workday the injured or ill employee would other-
wise have worked, the employee’s work has been restricted and the case must be
recorded.
How is a case recorded where the worker works only for a partial work shift because
of a work-related injury or illness?
A partial day of work is recorded as a day of job transfer or restriction for recordkeeping
purposes, except for the day on which the injury occurred or the illness began.
How are vague restrictions such as “light duty” or “take it easy for a week” handled?
If an employer is not clear about the physician or other licensed health care profes-
sional’s recommendation, they may ask that person whether the employee can do all
of his or her routine job functions and work all of his or her normally assigned work shift.
If the answer to both of these questions is ‘yes,’ then the case does not involve a work
restriction and does not have to be recorded as such. If the answer to one or both of

these questions is ‘no,’ the case involves restricted work and must be recorded as a
restricted work case.
If the employer is unable to obtain this additional information from the physician or other
licensed health care professional who recommended the restriction, record the injury or
illness as a case involving restricted work.
What if an employee does all of his or her routine job functions despite recom-
mended work restrictions?
The injury or illness must be recorded on the OSHA 300 Log as a restricted work case.
If a physician or other licensed health care professional recommends a job restriction,
the employer should ensure that the employee complies with that restriction. If the
employer receives recommendations from two or more physicians or other licensed
health care professionals, a decision must be made as to which recommendation is the
most authoritative, and the case must be recorded based upon that recommendation.
If an employee who routinely works ten hours a day is restricted from working more
than eight hours following a work-related injury, is the case recordable?
Generally, the employer must record any case in which an employee’s work is restricted
because of a work-related injury. A work restriction, as defined in 1904.7(b)(4)(i)(A),
occurs when the employer keeps the employee from performing one or more routine
functions of the job, or from working the full workday the employee would otherwise
have been scheduled to work. In this situation, the case is recordable if the employee
would have worked 10 hours had he or she not been injured.
How long must a modification to a job last before it can be considered a permanent
modification?
A permanent restriction or transfer is one that is expected to last for the remainder of
the employee’s career. Where the restriction or transfer is determined to be permanent
at the time it is ordered, the employer must count at least one day of the restriction or
transfer on the Log. If the employee whose work is restricted or who is transferred to
another job is expected to return to his or her former job duties at a later date, the
restriction or transfer is considered temporary rather than permanent.
An employee has a work-related shoulder injury resulting in days of restricted work

activity. While working on restricted duty, the employee sustains a foot injury which
results in a different work restriction. How would the employer record these cases?
The employer would stop the count of the days of restricted work activity due to the first
case, the shoulder injury, and enter the foot injury as a new case and record the number
of restricted work days. If the restriction related to the second case, the foot injury, is
lifted and the employee is still subject to the restriction related to their shoulder injury,
the employer must resume the count of days of restricted work activity for that case.

Work-Relatedness
How is work-relatedness determined?

The employer must consider an injury or illness to be work-related if an event or
exposure in the work environment either caused or contributed to the resulting con-
dition or significantly aggravated a pre-existing injury or illness. Work-relatedness is
presumed for injuries and illnesses resulting from events or exposures occurring in the
work environment, unless an exception in 1904.5(b)(2) specifically applies.
What is the “work environment?”

OSHA defines the work environment as “the establishment and other locations where
one or more employees are working or are present as a condition of their employment.
The work environment includes not only physical locations, but also the equipment or
materials used by the employee during the course of his or her work.”
Further, OSHA says in the Recordkeeping Handbook that “injuries and illnesses also
occur at work that do not have a clear connection to a specific work activity, condition,
or substance that is peculiar to the employment environment. For example, an
employee may trip for no apparent reason while walking across a level factory floor; be
sexually assaulted by a co-worker; or be injured accidentally as a result of an act of
violence perpetrated by one co-worker against a third party. In these and similar cases,
the employee’s job-related tasks or exposures did not create or contribute to the risk
that such an injury would occur. Instead, a causal connection is established by the fact
that the injury would not have occurred but for the conditions and obligations of employ-
ment that placed the employee in the position in which he or she was injured or made
ill.”
Even though the employee was not engaged in activities associated with her job in the
above situations, OSHA says that there is a ‘geographic presumption’’ of work-
relatedness.
Are there situations where an injury or illness occurs in the work environment and is
not considered work-related?
Yes, an injury or illness occurring in the work environment that falls under one of the
exceptions in 1904.5(b)(2) is not work-related, and therefore is not recordable.
What if it is not obvious whether the event or exposure occurred in the work envi-
ronment or away from work?
In these situations, the employer must evaluate the employee’s work duties and envi-
ronment to decide whether or not one or more events or exposures in the work
environment either caused or contributed to the resulting condition or significantly
aggravated a pre-existing condition.

How does an employer determine if an event or exposure in the work environment

“significantly aggravated” a preexisting injury or illness?
OSHA says that apreexisting injury or illness has been significantly aggravated when
an event or exposure in the work environment results in any of the following:
• Death provided that the preexisting injury or illness would likely not have
resulted in death but for the occupational event or exposure.
• Loss of consciousness provided that the preexisting injury or illness would
likely not have resulted in loss of consciousness but for the occupational event
or exposure.
• One or more days away from work, or days of restricted work, or days of job
transfer that otherwise would not have occurred but for the occupational event
or exposure.
• Medical treatment in a case where no medical treatment was needed for the
injury or illness before the workplace event or exposure, or a change in
medical treatment was necessitated by the workplace event or exposure.
Is an injury or illness work-related if the employee is traveling at the time the injury
or illness occurs?
Injuries and illnesses that occur while an employee is traveling are work-related if, at
the time of the injury or illness, the employee was engaged in work activities “in the
interest of the employer.” Examples of such activities include:
• Travel to and from customer contacts;
• Conducting job tasks; and
• Entertaining or being entertained to transact, discuss, or promote business
(work-related entertainment includes only entertainment activities being
engaged in at the direction of the employer).
Injuries or illnesses that occur when the employee is traveling do not have to be
recorded if the employee has:
• Checked into a hotel or motel for one or more days – When a traveling
employee checks into a hotel, motel, or into a other temporary residence, he
or she establishes a “home away from home.” The employer must evaluate
the employee’s activities after checking in for their work-relatedness in the
same manner as the employer would evaluate the activities of a non-traveling
employee. When the employee checks into the temporary residence, he or
she is considered to have left the work environment. When the employee
begins work each day, he or she re-enters the work environment. If the
employee has established a “home away from home” and is reporting to a
fixed worksite each day, you also do not consider injuries or illnesses work-
related if they occur while the employee is commuting between the temporary
residence and the job location.
• Taken a personal detour from a reasonably direct route of travel (i.e., has
taken a side trip).

How is it decided if a case is work-related when the employee is working from home?
Injuries and illnesses that occur while an employee is working at home, including work
in a home office, will be considered work-related if the injury or illness occurs while the
employee is performing work for pay or compensation in the home, and the injury or
illness is directly related to the performance of work rather than to the general home
environment or setting.
For example, if an employee drops a box of work documents and injures his or her foot,
the case is considered work-related. If an employee is injured because he or she trips
on the family dog while rushing to answer a work phone call, the case is not considered
work-related. If an employee working at home is electrocuted because of faulty home
wiring, the injury is not considered work-related.
What are “assigned working hours?”

“Assigned working hours” means those hours the employee is actually expected to
work, including overtime.
If an employee stays at work after normal work hours to prepare for the next day’s
tasks and is injured, is the case work-related?
A case is work-related any time an event or exposure in the work environment either
causes or contributes to an injury or illness or significantly aggravates a pre-existing
injury or illness, unless one of the exceptions in 1904.5(b)(2) applies. The work envi-
ronment includes the establishment and other locations where one or more employees
are working or are present as a condition of their employment. This case would be
work-related if the employee was injured as a result of an event or exposure at work,
regardless of whether the injury occurred after normal work hours.
An employee experienced an injury or illness in the work environment before they

had “clocked in” for the day. Is the case considered work- related even if that
employee was not officially “on the clock” for pay purposes?
Yes, injuries and illnesses occurring in the work environment are considered work-
related. Punching in and out with a time clock (or signing in and out) does not affect the
outcome for determining work-relatedness. If the employee experienced a work-related
injury or illness, and it meets one or more of the general recording criteria in 1904.7, it
must be entered on the employer’s OSHA 300 log.

If an employee’s pre-existing medical condition (e.g., epilepsy) causes an incident

which results in a subsequent injury, is the case work-related?
Injuries and illnesses that result solely from non-work-related events or exposures are
not recordable under the exception in 1904.5(b)(2)(ii). Epileptic seizures are a symptom
of a disease of non-occupational origin, and the fact that they occur at work does not
make them work-related. Because epileptic seizures are not work-related, injuries
resulting solely from the seizures (e.g., a broken arm) are not recordable.

Inspections
Checklists
What should be included on an inspection checklist?

Many companies find it helpful to use checklists for inspections to ensure that important
items are not overlooked. If they’re helpful, that’s fine; but inspectors should be trained
to question anything which doesn’t appear safe or proper. They should not limit them-
selves to only what is on the checklist.
When developing a checklist, consider:
• Past problems,
• Standards which apply to your industry,
• Specific standards of concern to your facility,
• Input from employees,
• The company’s standard safety practices,
• Training completed by employees, and
• Work from job procedures or job safety analyses.
Checklists should avoid excessive detail, vague criteria, and forms or attachments that
overwhelm. Remember, these are just tools to aid individuals during an inspections.
Once team members are skilled inspectors, they may not need checklists.
Corrective Actions
What must an employer do if an inspection identifies a hazard?

No inspection is effective unless each identified hazard or hazardous condition is
immediately corrected or appropriately scheduled for correction. Therefore, the goal
must be to find any and all deficiencies and fix them before they lead to an incident or
an inspection by OSHA. Inspections are often a last line of defense. This is why they
are the key to a successful safety and health management program.
A formal written procedure should be developed to ensure that effective corrective
actions are taken when non-compliance issues are found during the inspection. This
should be done in a timely manner. If problems are identified in an inspection and
9/12 Inspections–1
nothing is done to correct the situation, this information could be used against a com-
pany in future enforcement proceedings.
Equipment
Is special equipment necessary to conduct inspections?

The equipment that is brought into an area will depend upon several factors, including
how in-depth the inspection will be, what is being inspected, and the background of the
inspector. This could include a camera, flashlight, personal protective equipment, sam-
pling devices, electrical testing equipment, and paper and pen or pencil. If some
inspection team members are not certified or knowledgeable on how to use some of the
safety equipment, provide additional training or additional personnel with the required
knowledge.
Frequency
How often must inspections be conducted?

How often inspections must be conducted is dictated by the applicable OSHA standard,
which varies considerably. If not specified in a standard, then management should
decode how often inspections will be conducted. This can be annually, semi-annually,
bi-monthly, monthly, weekly, or even daily. Deciding how often inspections should take
place can be difficult; therefore, employers should conduct a survey of the workplace
to help in this determination.
Once a survey has been completed, two things should be considered:
• If any area has the potential to cause excessive accidents, and
• How severe the accident would be if it occurred within the area.
Some employers make it standard policy to inspect all of their facilities and equipment
at least annually, with more frequent inspections for high hazard or production areas.
Others do complete inspections more frequently than once a year, depending on the
risks the company faces. It is up to each employer to assess the relative risks at the
company and develop an adequate safety inspection schedule.
And keep in mind that the day after an inspection an unlabeled container can reappear.
Remember that an inspection is a “snapshot” in time of a company’s safety compliance.
2–Inspections 9/12
When is the best time to conduct inspections?

Although spot inspections of equipment and procedures are useful, it is helpful to
arrange schedules where most of the equipment will be operating and employees will
be working. On the other hand, the inspection team should ensure their work can be
carried out at a time and in a way that it does not interfere with production processes.
Avoid particularly heavy workflow periods, unless the point of the inspection is to see
if those time periods generate more hazards than at other times.
Personnel
Who must perform inspections?

Generally, inspections are performed by a member or a team of members from the
safety committee. In addition, supervisors, maintenance personnel, engineers, etc.
may conduct inspections or be part of the inspection team. These individuals will
provide valuable insight into particular production processes or work hazards unique to
the area. Additional benefits include the following:
• Questions about equipment and processes can be answered immediately.
• Some infractions may be able to be fixed on the spot.
• Utilizing several people to do inspections improves the odds of finding haz-
ards.
• Individuals responsible for safety and health are kept in touch with the suc-
cesses and/or problems in the workplace.
• Involvement increases employee awareness of the safety and health pro-
gram.
Consider rotating inspection personnel on a regular basis. Those who work in or super-
vise a particular area can start “not seeing” things that they get used to seeing every
day. Remember, new eyes see different things.
Recordkeeping
Are employers required to keep inspection records?

In some instances, OSHA requires inspections be documented. Typically, if documen-
tation is required, the employer must generate a certification record of the inspection
which includes (at a minimum):
• The date of the inspection;
• The signature of the person who performed the inspection; and
• The number, or other identifier, of the item which was inspected.

Inspection records must be retained and made available for review as required by the
applicable OSHA standard.
Is there a required format that must be used for inspection records?

There is no required format; however, when documenting inspection observations and
findings, a standard format and approach helps keep things organized. Make the form
or report easy to follow and use. This will better ensure proper usage and understand-
ing by the employees responsible for inspection activities and also facilitate all
reviewers’ ability to understand the observations and findings.
Will OSHA request to see our inspection records?

OSHA will not routinely request to examine self-inspection records and will not use
them as a means of identifying areas to focus on during an inspection. In addition, the
agency won’t cite employers in cases where they have identified a hazard during a
self-inspection and have promptly undertook appropriate corrective measures to cor-
rect the hazard. It is OSHA’s policy to recognize the value of voluntary self-inspection
programs that are designed to allow employers to identify and promptly correct haz-
ardous conditions.
Required Inspections
Must employers conduct inspections?

Yes, certain inspections are required. These are outlined in a number of OSHA stan-
dards. Generally, employers must inspect the work environment, equipment, and/or
processes at specified intervals.
The following table provides a summary of required OSHA inspections for general
industry. Each entry describes what must be inspected, when it must be inspected, and
any associated recordkeeping requirements. Employers should refer to the actual regu-
lation for clarification and further guidance.
Required General Industry OSHA Inspections At-A-Glance

Category: Portable Wood Ladders (1910.25)
When: Frequently.
What: Inspect for:
• Sharp edges,
• Splinters,
• Shake,
• Wane,
• Compression failures,
• Decay, and
• Other irregularities.
Ladders must be sound.
Recordkeeping: None required.
Category: Portable Metal Ladders (1910.26)
When: Immediately when:
• A ladder tips over, or
• A ladder is exposed to oil and grease.
What: Inspect:
• Side rails for dents or bends,
• Rungs for excessive dents,
• Rung-to-side-rail and hardware connections, and
• Rivets for shear.
Clean ladders of oil, grease, or slippery materials.
Category: Fixed Ladders (1910.27)
When: Regularly with intervals between inspections determined by use
and exposure.
What: Inspect:
• Metal ladders for corrosion, rusting, and other deterioration;
• Wood ladders for accumulation of water;
• Wood parts for sharp edges, splinters, shake, wane, compres-
sion failures, decay, or other irregularities; and
• Side rails, rungs, cleats, and steps for splinters, sharp edges, or
burrs.
Fixed ladders must be maintained in a safe condition.
Category: Safety Requirements for Scaffolding (1910.28)

Tubular welded frame scaffolds
When: Periodically.
What: Inspect all welded frames and accessories for any:
• Broken,
• Bent,
• Excessively rusted,
• Altered, or
• Otherwise structurally damaged frames or accessories.
Any welded frames or accessories that require maintenance
(including painting) or minor corrections authorized by the manu-
facturer must be made before further use.
Masons’ adjustable multiple-point suspension scaffolds

When: Before each installation and periodically thereafter.
What: Inspect all parts of the scaffold to ensure they are maintained in
sound and good working condition. This includes:
• Bolts,
• Nuts,
• Fittings,
• Clamps,
• Wire rope, and
• Outrigger beams and their fastenings.
Two-point suspension scaffolds (swinging scaffolds)

When: Before every installation and periodically while the scaffold is in
use.
What: Inspect all:
• Wire ropes,
• Fiber ropes,
• Slings,
• Hangers,
• Platforms, and
• Other supporting parts.
Single-point adjustable suspension scaffolds

When: After each installation and every 30 days thereafter.
What: Inspect:
• Hoisting machines,
• Cables, and
• Equipment.
Interior hung scaffolds

When: Before the scaffold is erected.
What: Inspect all overhead supporting members for strength to ensure
that the rope used for suspension is capable of supporting at least
six times the intended load.
Category: Powered Platforms for Building Maintenance (1910.66)
Installations and alterations
When: In the field before being placed in initial service.
What: Inspect all completed building maintenance equipment installations
to determine that:
• All parts conform to applicable requirements, and
• All safety and operating equipment is functioning as required.
When: After any major alteration to an existing installation.

What: Similarly inspect (and test) building maintenance installations as
indicated above.
When: Periodically at intervals not exceeding 12 months.

What: A competent person must inspect related building supporting struc-
tures.
When: At intervals specified by the manufacturer/supplier, but not to

exceed 12 months.
What: A competent person must inspect all parts of the equipment includ-
ing control systems. Parts subject to wear (e.g., wire ropes,
bearings, gears, and governors) must be inspected to determine
that they have not worn to such an extent as to affect the safe
operation of the installation.
Recordkeeping: The building owner must keep a certification record of each inspec-
tion (and test) that includes:
• The date of the inspection;
• The number, or other identifier, of the building support structure
and equipment which was inspected.
Working platforms
When: Before every use and after each occurrence which could affect the
platform’s structural integrity.
What: The employer must inspect working platforms and their compo-
nents.
Maintenance
When: Prior to each work cycle or every 30 days.
What: A competent person must perform a maintenance inspection of
each platform installation following procedures recommended by
the manufacturer.
Governors and secondary brakes

When: At intervals specified by the manufacturer/supplier, but not to
exceed every 12 months.
What: A competent person must inspect governors and secondary
brakes.
When: Before each days use where testing is not feasible.

What: Visually inspect the secondary brake governor and actuation
device to ensure that it is free to operate.
Suspension wire ropes

When: Before every use and after each occurrence which might affect the
ropes’ integrity.
What: A competent person must inspect the ropes for visible defects and
gross damage.
When: If in service: Once a month

If inactive for 30 days or longer: Before the ropes are placed into
service.
What: A competent person must conduct a thorough inspection of the

ropes for:
• Broken wires exceeding three wires in one strand or six wires in
one rope lay;
• Distortion of rope structure such as would result from crushing or
kinking;
• Evidence of heat damage;
• Evidence of rope deterioration from corrosion;
• A broken wire within 18 inches (460.8 mm) of the end attach-
ments;
• Noticeable rusting and pitting;
• Evidence of core failure (a lengthening of rope lay, protrusion of
the rope core, and a reduction in rope diameter suggests core
failure);
• More than one valley break (broken wire);
• Outer wire wear that exceeds 1/3 of the original outer wire diam-
eter; or
• Any other condition which the competent person determines has
significantly affected the integrity of the rope.
If any of the above conditions are present, the wire rope must be
removed and replaced.
Hoist
When: Each day before lowering personnel below the top elevation of the
building.
What: Test the hoist in the lifting direction with the intended load to make
certain it has sufficient capacity to raise personnel back to the
boarding level.
Category: Personal Fall Arrest System (Appendix C to 1910.66, Section 1
- Mandatory)
When: Prior to use.
What: Inspect personal fall arrest systems for:
• Mildew,
• Wear,
• Damage, and
• Other deterioration.
Defective components must be removed from service if their
strength or function may be adversely affected.
When: When subjected to impact loading.

What: A competent person must inspect the personal fall arrest system or
components to determine that they are undamaged and suitable for
reuse.
Category: Vehicle-mounted Elevating and Rotating Work Platforms
(1910.67)
When: Before moving an aerial lift for travel.
What: Inspect the boom(s) to ensure that it is:
• Properly cradled, and
• Outriggers are in the stowed position.
Exception: Aerial lift trucks specifically designed to be moved
when the boom is elevated in a working position.
Category: Manlifts (1910.68)
When: Periodically at intervals of not more than 30 days.
What: A competent, designated person must conduct an inspection that
covers, but is not limited to, the following items:
• Steps,
• Step fastenings,
• Rails,
• Rail supports and fastenings,
• Rollers and slides,
• Belt and belt tension,
• Handholds and fastenings,
• Floor landings,
• Guardrails,
• Lubrication,
• Limit switches (must be inspected weekly),
• Warning signs and lights,
• Illumination,
• Drive pulley,
• Bottom (boot) pulley clearance,
• Pulley supports,
• Motor,
• Driving mechanism,
• Brake,
• Electrical switches,
• Vibration and misalignment, and
• “Skip” on up or down run when mounting step.
Recordkeeping: A certification record must be kept of each inspection that includes:

• The date;
• The serial number, or other identifier, of the manlift which was
inspected.
Category: Ventilation (1910.94)
Blast-cleaning enclosures
When: Regularly.
What: Inspect slit abrasive-resistant baffles.
Exhaust ventilation systems

When: When the installation is complete and periodically thereafter.
What: The static pressure drop at the exhaust ducts leading from the
equipment to assure continued satisfactory operation.
Additional inspection of the exhaust system must be conducted as
set forth in American National Standard Institute (ANSI) Z9.2-1960
and ANSI Z33.1-1961.
Category: Compressed Gases - General Requirements (1910.101)
When: As prescribed in the Department of Transportation hazardous
materials regulations under 49 CFR Parts 171-179 and 14 CFR
Part 103. If not applicable, then as prescribed in Compressed Gas
Association Pamphlets C-6-1998 and C-8-1962.
What: Inspect compressed gas cylinders to determine (to the extent pos-
sible) that they are in safe condition.
Category: Hydrogen (1910.103)
When: If out of service in excess of one year.
What: Inspect the safety relief devices to determine if they are operable
and properly set.
Category: Flammable Liquids (1910.106)
Industrial plants
Portable and special equipment
When: Periodically.
What: Inspect all plant fire protection facilities to make sure they are in
satisfactory operating condition and will serve their purpose in time
of emergency.
Equipment repairs
When: Unspecified.
What: The individual in responsible charge must inspect the area(s)
where hot work (e.g., welding or cutting operations), use of spark-
producing power tools, and chipping operations are conducted to
be sure that it is safe for the work to be done and that safe proce-
dures will be followed for the work specified.
Bulk plants
Hoses and couplings
When: At intervals appropriate to the service.
What: Inspect all pressure hoses and couplings by performing a test with
the hose extended and using the “inservice maximum operating
pressures” to determine material deteriorations, signs of leakage,
or weakness in the hose carcass or at the couplings.
Processing plants (except chemical plants, refineries, and dis-

tilleries)
Portable fire extinguishers
When: Periodically.
What: Inspect all plant fire protection facilities to make sure they are in
satisfactory operating condition and will serve their purpose in time
of emergency.
Maintenance and repair

When: Unspecified.
What: The individual in responsible charge must inspect the area(s)
where hot work (e.g., welding or cutting operations), use of spark-
producing power tools, and chipping operations are conducted to
be sure that it is safe for the work to be done and that safe proce-
dures will be followed for the work specified.
Category: Spray Finishing Using Flammable and Combustible Materials
(1910.107)
Spray booths
When: Unspecified
What: Inspect dry type spray booth filter rolls to ensure proper replace-
ment of filter media.
Recordkeeping: None required
Flammable liquids and liquids with a flashpoint greater than

199.4°F (93°C)
When: At regular intervals appropriate to the service.
What: Inspect all pressure hoses and couplings on all containers or piping
by performing a test with the hose extended and using the
“inservice maximum operating pressures” to determine material
deteriorations, signs of leakage, or weakness in the hose carcass
or at the couplings.
Category: Explosives and Blasting Agents (1910.109)
Transportation vehicles
When: As often as necessary to determine that the motor vehicle is in
proper condition for the safe transportation of explosives.
What: Inspect the vehicle to ensure that:
• Fire extinguishers are filled and in working order;
• All electrical wiring is completely protected and securely fas-
tened to prevent short-circuiting;
• The chassis, motor, pan, and underside of the body is reason-
ably clean and free of excess oil and grease;
• The fuel tank and feedline are secure and have no leaks;
• The brakes, lights, horn, windshield wipers, and steering appa-
ratus function properly; and
• The tires are properly inflated and are in proper condition in
every other respect and acceptable for handling explosives.
Fixed location mixing

When: Daily.
What: Visually inspect mixing, conveying, and electrical equipment to
establish that it is in good operating condition.
Category: Process Safety Management of Highly Hazardous Chemicals
(1910.119)
Management
When: Unspecified.
What: Inspect existing equipment designed and constructed in accor-
dance with codes, standards, or practices that are no longer in
general use to determine that the equipment is safe.
Recordkeeping: A record must be kept of each equipment inspection (see below).
When: At least every three years.
What: At least one personal knowledgeable about the process must con-
duct a compliance audit to verify that the procedures and practices
developed under the Process Safety Management standard are
adequate and being followed.
Recordkeeping: A report must be developed that includes:
• Audit findings,
• Responses to each of the findings, and
• Corrective actions to deficiencies.
The two most recent audit reports must be retained.
Process equipment
When: At intervals consistent with applicable manufacturers’ recommen-
dations and good engineering practices (more frequently if
determined to be necessary by prior operating experience).
What: Inspect process equipment following recognized and generally
accepted good engineering practices to assure that equipment is
installed properly and consistent with design specifications and the
manufacturer’s instructions.
Recordkeeping: A record must be kept of each inspection that includes:
• The date,
• The name of the person who performed the inspection,
• The serial number, or other identifier, of the equipment which
was inspected;
• A description of the inspection; and
• The results of the inspection.
Category: Hazardous Waste Operations and Emergency Response
(1910.120)
Safety and health program
When: As necessary.
What: The site safety and health supervisor (or another individual who is
knowledge in occupational safety and health) must conduct inspec-
tions to determine the effectiveness of the site safety and health
plan.
Recordkeeping: A written safety and health program must be kept on site.
Equipment
When: Prior to use.
What: Inspect all equipment to be used during clean-up work after the
emergency response is complete to ensure that it is in serviceable
condition.
Drums and containers

When: If practical: Prior to being moved.
If not practical due to storage conditions: Prior to further han-
dling after being moved to an accessible location.
What: Inspect for ruptures, leakage, spillage, etc. to ensure the integrity of
the drum and/or container.
Category: Dipping and Coating Operations - General Requirements
(1910.124)
Ventilation system
When: At least quarterly and prior to operation after a prolonged shut-
down.
What: Inspect the hoods and ductwork to ensure:
• There is no corrosion or damage, and
• The airflow is adequate.
Dipping and coating equipment

When: Periodically.
What: Inspect all dipping and coating equipment, including:
• Covers,
• Drains,
• Overflow piping, and
• Electrical and fire extinguishing systems.
Deficiencies must be promptly corrected.
Category: Respiratory Protection (1910.134)
Routine use respirators
When: Before each use and during cleaning.
What: Inspect respirators for:
• Proper function;
• Tightness of connections;
• Condition of the parts (i.e., facepiece, head straps, valves, con-
necting tube, cartridges, canisters, filters, etc.); and
• Pliability and signs of deterioration (elastomeric parts).
Emergency use respirators

When: At least monthly and before and after each use.
What: Inspect respirators, in accordance with the manufacturer’s recom-
mendations, for:
Recordkeeping: A certification document must be kept of each inspection that
includes:
• The date;
• The name (or signature) of the person who performed the
inspection;
• The serial number, or other identifier, of the respirator which was
inspected;
• The findings of the inspection; and
• The required remedial action of the inspection.
Inspection information must be:
• On a tag or label that is attached to the storage compartment for
the respirator or kept with the respirator, or
• Included in inspection reports stored as paper or electronic files.
The information must be maintained until it is replaced following a
subsequent certification.
Emergency escape-only respirators

When: Before being carried into the workplace.
Self-containing breathing apparatus respirators

When: Monthly
• Proper function (including the regulator and warning devices);
necting tube, cartridges, canisters, filters, etc.);
• Pliability and signs of deterioration (elastomeric parts); and
• Pressure level in the air and oxygen cylinders.
Air and oxygen cylinders must be kept in a fully charged state and
be recharged when the pressure falls to 90% of the manufacturer’s
recommended pressure level.
Category: Head Protection (1910.135)
When: Daily*.
What: Visually inspect* protective helmets (hard hats) purchased after
July 5, 1994 and all components for such things as:
• Dents;
• Cracks;
• Penetration; and
• Damage due to impact, rough treatment, or wear.
*As prescribed in ANSI Z89.1-1986, “American National Standard
for Personnel Protection - Protective Headwear for Industrial
Workers-Requirements,” and incorporated by reference.
Category: Electrical Protective Equipment (1910.137)
When: Before each day’s use and immediately following any incident that
can reasonably be suspected of having caused damage.
What: Inspect insulating equipment (i.e., blankets, covers, line hoses,
gloves, and sleeves made of rubber) for the following:
• Holes, tears, punctures, or cuts;
• Ozone cutting or checking;
• Embedded foreign objects;
• Texture changes such as swelling, softening, hardening, sticki-
ness, or inelasticity; and
• Any other defect that damages the insulating properties.
Damaged or defective insulating equipment may not be used.
Category: The Control of Hazardous Energy - Lockout/tagout (1910.147)

Energy control procedure
When: At least annually.
What: Where lockout is used: An authorized employee, other than the
one(s) utilizing the energy control procedure, must conduct an
inspection that includes an observation of the implementation of
the procedure and a review of each authorized employee’s respon-
sibilities under the energy control procedure being inspected.
Where tagout is used: An authorized employee, other than the
the procedure and a review of each authorized and affected
employee’s responsibilities under the energy control procedure
being inspected and the following:
• Tags are used only as warning devices and not as a physical
restraint on energy isolating devices that would otherwise require
the use of a lock;
• Tags are not removed without authorization of the authorized
person responsible for it or that it has not been bypassed,
ignored, or otherwise defeated;
• Tags are legible and understandable by all authorized employ-
ees, affected employees, and all other employees who work
operations are or may be in the area;
• Tags and their means of attachment are made of materials which
will withstand the environmental conditions encountered in the
workplace;
• Tags are securely attached to energy isolating devices so that
they cannot be inadvertently or accidentally detached during
use; and
• The meaning of tags is understood by employees as part of the
overall energy control program.
Any deviations or inadequacies found during the inspection must
be corrected.
Recordkeeping: A certification document must be kept of inspections that includes:
• The date;
• The name of the employees included in the inspection;
• The name of the person who performed the inspection; and
The name, or other identifier, of the machine or equipment on
which the energy control procedure was being utilized.
Machines or equipment
When: Before lockout or tagout devices are removed and energy is
restored.
What: The authorized employee must inspect the work area to ensure
that nonessential items have been removed and that machine or
equipment components are operationally intact.
Employees
restored.
What: The authorized employee must check the work area to ensure that
all employees have been safely positioned or moved.
Category: Fire Brigades (1910.156)
Fire fighting equipment

What: Inspect fire fighting equipment to assure safe operational condition.
Equipment that is in damaged or unserviceable condition must be
removed from service and replaced.
Portable fire extinguishers and respirators

When: At least monthly.
What: Inspect portable fire extinguishers and respirators to assure safe
operational condition.
Equipment that is in damaged or unserviceable condition must be
removed from service and replaced.
Category: Portable Fire Extinguishers (1910.157)

When: Monthly.
What: Visually inspect portable extinguishers (or hose if used in lieu
thereof) to ensure, at a minimum, the following:
• It is in its designated place;
• The appropriate type is present;
• It is readily accessible (i.e., there are no obstructions to access
or visibility);
• It is pressurized;
• Safety seals and tamper indicators are not broken or missing;
• Pressure gauge reading or indicator is in the operable range or
position;
• Operating instructions on the nameplate are legible and facing
outward;
• Required labels are in place; and
• There is no obvious physical damage or defects (e.g., corrosion,
leakage, mechanical damage, welding, soldering, brazing, pos-
sible tampering, etc.).
Category: Standpipe and Hose Systems (1910.158)
Hose systems
When: At least annually and after each use.
What: A designated trained person must inspect hose systems to assure
that all of the equipment and hose are in place, available for use,
and in serviceable condition.
Hemp or linen hose

What: A designated trained person must ensure that hemp or linen hose
on existing systems is unracked, physically inspected for deterio-
ration, and reracked using a different fold pattern.
A defective hose must be replaced.
Category: Fixed Extinguishing Systems - General (1910.160)
The system
When: Annually.
What: A trained employee knowledgeable in the design and function of
the system must conduct an inspection to assure that it is main-
tained in good operating condition.
Refillable containers
When: At least semi-annually.
What: A trained employee must inspect the weight and pressure of refill-
able containers.
If the container has a loss in net content or weight of more than 5
percent or a loss of pressure more than 10 percent, it must be
corrected.
Recordkeeping: The date of the inspection (and any required maintenance) must be
recorded:
• On the container,
• On a tag attached to the container, or
• In a central location.
A record of the last semi-annual check must be maintained until the
container is checked again or for the life of the container, whichever
is less.
Non-refillable containers
What: A trained employee must inspect the weight of non-refillable con-
tainers which have no means of pressure indication.
If the container shows a loss in net weight or more than 5 percent
it must be replaced.
If the container has a loss in net content or weight of more than 5
percent or a loss of pressure more than 10 percent, it must be
corrected.
Recordkeeping: The date of the inspection (and any required maintenance) must be
recorded:
• On the container,
• On a tag attached to the container, or
• In a central location.
A record of the last semi-annual check must be maintained until the
container is checked again or for the life of the container, whichever
is less.
Category: Servicing Multi-piece and Single Piece Rim Wheels (1910.177)

Tire servicing equipment
When: Prior to each day’s use and after any separation of the rim wheel
components or sudden release of contained air.
What: Visually inspect restraining devices and barriers for:
• Cracks at welds;
• Cracked or broken components;
• Bent or sprung components caused by mishandling, abuse, tire
explosion, or rim wheel separation;
• Pitting components due to corrosion; or
• Other structural damage which would decrease its effectiveness.
Defective equipment must be immediately removed from service.
Wheel components
When: Prior to assembly.
What: Inspect multi-piece wheel components and single piece wheels for:
• Bends affecting the shape,
• Pits from corrosion,
• Breaks,
• Cracks,
• Damaged or leaky valves.
Defective wheel and wheel components may not be used and must
be marked or tagged unserviceable and removed from the service
area.
Operation
When: After tire inflation.
What: Inspect tire and wheel components while still within the restraining
device to make sure that they are properly seated and locked.
Category: Powered Industrial Trucks (1910.178)
When: At least daily before use and after each shift when the vehicle is
being used around the clock.
What: Inspect the forklift for conditions which may adversely affect the
safety of the vehicle in accordance with the manufacturer’s recom-
mendations.
Defects must be immediately reported and corrected.
Category: Overhead and Gantry Cranes (1910.179)

New and altered cranes
When: Prior to initial use.
What: Inspect:
• All functional operating mechanisms for maladjustment interfer-
ing with proper operation;
• Lines, tanks, valves, drain pumps, and other parts of the air or
hydraulic systems for deterioration or leakage;
• Hooks for deformation or cracks ;
• Hoist chains, including end connections, for excessive wear,
twist, distorted links that interfere with proper function or stretch
beyond the manufacturer’s recommendations;
• All functional operating mechanisms for excessive wear of com-
ponents;
• Rope reeving for noncompliance with the manufacturer’s recom-
mendations; and
• Running ropes for deterioration that would result in appreciable
loss of original strength.
All deficiencies must be carefully examined to determine whether
they constitute a safety hazard.
Cranes in regular use

When: Frequently: Daily to monthly intervals dependent on the nature of
the critical components of the crane and the degree of their expo-
sure to wear, deterioration, or malfunction.
What: Inspect:
ing with proper operation (daily inspection required);
hydraulic systems for deterioration or leakage (daily inspection
required);
• Hooks for deformation or cracks (daily inspection required);
beyond the manufacturer’s recommendations (daily inspection
required);
ponents;
mendations; and
• All ropes for deterioration that would result in appreciable loss of
original strength (at least monthly inspection required).
Recordkeeping: A certification document must be generated monthly of hook, hoist
chain, and rope* inspections that includes:
• The date;
• A serial number, name, or other identifier of the hook, chain, or
rope that was inspected.
*Rope inspection records must be kept on file where readily avail-
able to appointed personnel.
When: Periodically: 1 to 12-month intervals dependent upon the crane’s

activity, severity of service, and environment in which it is used.
What: Inspect:
• Hooks for deformation or cracks;
ponents;
mendations;
• Deformed, cracked, or corroded members;
• Loose bolts or rivets;
• Cracked or worn sheaves and drums;
• Worn, cracked, or distorted parts (e.g., pins, bearings, shafts,
gears, rollers, locking, and clamping devices);
• Excessive wear on brake system parts, linings, pawls, and ratch-
ets;
• Load, wind, and other indicators over their full range for any
significant inaccuracies;
• Gasoline, diesel, electric, or other power plants for improper per-
formance or noncompliance with applicable safety requirements;
• Chain drive sprockets for excessive wear and excessive chain
stretch;
• Electrical apparatus for signs of pitting or any deterioration of
controller contactors, limit switches, and pushbutton stations;
and
• All ropes for deterioration by an appointed person whose
approval is required for further use of the rope (at least monthly
inspection required).
Recordkeeping: A certification document must be generated monthly of hook, hoist
chain, and rope* inspections that includes:
• The date;
• A serial number, name, or other identifier of the hook, chain, or
rope that was inspected.
*Rope inspection records must be kept on file where readily avail-
able to appointed personnel.
Cranes which have been idle for one month or more, but less than
six months
When: Before placing in service.
What: Inspect:
ponents;
mendations; and
approval is required for further use of the rope.
Recordkeeping: A certification document must be generated of the rope inspection
that includes:
• The date;
• An identifier for the ropes that were inspected.
The record must be made available for inspection.
Cranes which have been idle for more than six months
What: Inspect:
ponents;
mendations;
• Deformed, cracked, or corroded members;
gears, rollers, locking, and clamping devices);
• Brake system parts, linings, pawls, and ratchets for excessive
wear;
• Load, wind, and other indicators over their full range for any
significant inaccuracies;
stretch;
• Electrical apparatus for signs of pitting or any deterioration of
controller contactors, limit switches, and pushbutton stations;
and
that includes:
• The date;
Standby cranes
What: Inspect:
ponents;
mendations; and
that includes:
• The date;
Category: Crawler Locomotive and Truck Cranes (1910.180)

New and altered cranes
What: Inspect:
• All control mechanisms for maladjustment interfering with proper
operation;
• All control mechanisms for excessive wear of components and
contamination by lubricants or other foreign matter;
• All safety devices for malfunction;
• Air or hydraulic systems for deterioration or leakage;
• Electrical apparatus for malfunctioning and signs of excessive
deterioration, dirt, and moisture accumulation;
mendations; and
original strength by an appointed or authorized person whose
Cranes in regular use

When: Frequently: Daily to monthly intervals or if observation during
operation warrants more frequent inspection.
What: Inspect:
operation (daily inspection required);
mendations; and
Recordkeeping: A certification document must be generated monthly of critical

items in use (e.g., brakes, hooks, and ropes) that includes:
• The date;
• A serial number, name, or other identifier of the crane that was
inspected.
Inspection records must be kept on file where readily available.
When: Periodically: 1 to 12-month intervals (or as specifically recom-

mended by the manufacturer) depending upon the crane’s activity,
severity of service, and environment in which it is used.
What: Inspect:
operation;
mendations;
• Deformed, cracked, or corroded members in the crane structure
and boom;
gears, rollers, and locking devices);
wear;
• Load, boom angle, and other indicators over their full range for
any significant inaccuracies;
stretch;
• Travel steering, braking, and locking devices for malfunction;
• Tires for damage and excessive wear; and
Recordkeeping: A certification document must be generated monthly of critical
items in use (e.g., brakes, hooks, and ropes) that includes:
• The date;
• A serial number, name, or other identifier of the crane that was
inspected.
Inspection records must be kept on file where readily available.
Cranes which have been idle for one month or more, but less than
six months
What: Inspect:
operation;
mendations; and
• All ropes for all types of deterioration by an appointed or autho-
rized person whose approval is required for further use of the
rope.
that includes:
• The date;
Cranes which have been idle for six months

What: Inspect:
operation;
mendations;
• Deformed, cracked, or corroded members in the crane structure
and boom;
gears, rollers, and locking devices);
wear;
• Load, boom angle, and other indicators over their full range for
any significant inaccuracies;
stretch;
• Travel steering, braking, and locking devices for malfunction;
• Tires for damage and excessive wear; and
rope.
that includes:
• The date;
Standby cranes
When: At least semi-annually or more frequently if exposed to adverse
environmental conditions.
What: Inspect:
operation;
mendations; and
rope.
that includes:
• The date;
Category: Derricks (1910.181)

New and altered derricks
What: Inspect:
• All control mechanisms for adjustment, wear, and lubrication;
• All chords and lacing;
• Tension in guys;
• Plumb of the mast;
mendations;
• Hoist brakes, clutches, and operating levers for proper function;
and
original strength.
Derricks in regular use

When: Frequently: Daily to monthly intervals or if observation during
operation warrants more frequent inspection.
What: Inspect:
• All control mechanisms for adjustment, wear, and lubrication
(daily inspection required);
• All chords and lacing (daily visual inspection required);
• Tension in guys (daily inspection required);
• Air or hydraulic systems for deterioration or leakage (daily
inspection required);
mendations;
• Hoist brakes, clutches, and operating levers for proper function
(daily inspection before beginning operations required); and
that includes:
• The date;
When: Periodically: 1 to 12-month intervals depending upon the derrick’s

activity, severity of service, and environment in which it is used.
What: Inspect:
mendations;
• Structural members for deformations, cracks, and corrosion;
• Bolts and rivets for tightness;
• Pins, bearings, shafts, gears, sheaves, drums, rolling, and lock-
ing and clamping devices for wear, cracks, and distortion;
• Gudgeon pin for cracks, wear, and distortion (each time the der-
rick is to be erected);
• Power plants for proper performance and compliance with appli-
cable safety requirements;
• Foundation or supports for continued ability to sustain the
imposed loads; and
that includes:
• The date;
Derricks which have been idle for one month or more, but less than
six months
What: Inspect:
mendations;
and
• All ropes for all types of deterioration.
that includes:
• The date;
Derricks which have been idle for six months

What: Inspect:
mendations;
• Structural members for deformations, cracks, and corrosion;
• Bolts and rivets for tightness;
• Pins, bearings, shafts, gears, sheaves, drums, rolling, and lock-
ing and clamping devices for wear, cracks, and distortion;
• Gudgeon pin for cracks, wear, and distortion (each time the der-
rick is to be erected);
• Power plants for proper performance and compliance with appli-
cable safety requirements;
• Foundation or supports for continued ability to sustain the
imposed loads; and
that includes:
• The date;
• An identifier for the rope that was inspected.
Standby derricks
What: Inspect:
mendations;
and
that includes:
• The date;
• An identifier for the rope that was inspected.
Category: Helicopters (1910.183)
When: Prior to lifting a load.
What: Inspect the size and weight of loads and the manner in which they
are connected to the helicopter.
A lift may not be made if the helicopter operator believes the lift
cannot be made safely.
Category: Slings (1910.184)
When: Daily before use and during use where service conditions warrant.
What: A competent person designated by the employer must inspect the
sling and all fastenings for damage or defects.
Damaged or defective slings must be immediately removed from
service.
Alloy steel chain slings

When: Daily (as described above) and periodically (at least once every 12
months) based on:
• Frequency of sling use,
• Severity of service conditions,
• Nature of lifts being made, and
• Experience gained on the service life of slings used in similar
circumstances.
What: A competent person designated by the employer must inspect for
wear, defective welds, deformation, and increase in length.
Damaged or defective slings must be immediately removed from
service.
Recordkeeping: A record must be kept of the inspection pertaining to the most
recent month in which each alloy steel chain was inspected.
Category: Abrasive Wheel Machinery (1910.215)
When: Before mounting.
What: Inspect (and sound check per the “ring test”) all wheels to make
sure they have not been damaged in transit, storage, or otherwise
and that the spindle speed of the machine does not exceed the
maximum operating speed marked on the wheel.
Category: Mechanical Power Presses (1910.217)
General
When: Not less than weekly.
What: Inspect the clutch/break mechanism, anti-repeat features, single
stroke mechanism, auxiliary equipment, and other parts and safe-
guards on power presses to ensure safe operating condition and
adjustment.
Recordkeeping: A certification record must be generated that includes:
• The date;
• A serial number, or other identifier, of the press that was
inspected.
Pull-out devices
When: At the start of each operator’s shift, following a new die set-up, and
when operators are changed.
What: Visually inspect pull-out devices for proper adjustment

• The date;
• A serial number, or other identifier, of the press that was
inspected.
PSDI operation - Control systems

When: After power “one” and before the initial presence sensing device
initiation (PSDI) stroke.
What: Inspect control elements for correct status.
PSDI operation - Presence sensing device

When: At the beginning of each shift and whenever a die change is made.
What: Inspect presses equipped with a presence sensing device for use
in the PSDI mode (or for supplemental safeguarding on presses
used in the PSDI mode) to ensure:
• The device is operational;
• The safety distance is correct;
• All supplemental safeguarding is in place;
• The barrier and/or supplemental presence sending devices are
operating properly;
• Correct counterbalance adjustment for die weight according to
the press manufacturer’s instructions when equipped with a slide
counterbalance system; and
• That the bearings on flywheels running on journals on the crank-
shaft or back shaft or bullgears running on journals mounted on
the crankshaft are in good working order, properly lubricated,
and maintained in accordance with the press manufacturer’s rec-
ommendations.
Any press that reveals a condition of noncompliance, improper
adjustment, or failure cannot be operated until the condition has
been corrected by adjustment, replacement, or repair.
PSDI operation - Clutch and brake mechanisms

When: Periodically.
What: Inspect clutch and brake mechanisms on presses equipped with a
presence sensing device for use in the PSDI mode in accordance
with the press manufacturer’s recommendations to assure they are
in proper operating condition.
Any press that reveals a condition of noncompliance, improper
adjustment, or failure cannot be operated until the condition has
been corrected by adjustment, replacement, or repair.

Category: Forging Machines (1910.218)
Equipment
When: Periodically and at regular intervals.
What: Inspect all forge shop equipment to ensure continued safe opera-
tion.
• The date;
• A serial number, or other identifier, of the forging machine that
was inspected.
Guards and point of operation protection devices

When: Frequently and at regular intervals.
What: Inspect guards and point of operation protection devices to ensure
continued safe operation.
• The date;
• A serial number, or other identifier, of the equipment that was
inspected.
Category: Mechanical Power-Transmission Apparatus (1910.219)
When: At intervals not to exceed 60 days.
What: Inspect:
• Shafting for alignment, rust, excess oil or grease, and hazards of
static sparks;
• Bearing for alignment and proper adjustment;
• Hangers for tightness of supporting bolts and screws and hanger
boxes for proper adjustment;
• Pulleys for proper alignment; and
• Belts, lacings, fasteners, etc. to ensure good condition.
Category: Guarding of Portable Powered Tools (1910.243)
Abrasive wheels
When: Before mounting.
What: Inspect (and sound check per the “ring test”) all wheels to make
sure they have not been damaged in transit, storage, or otherwise
and that the spindle speed of the machine does not exceed the
maximum operating speed marked on the wheel.
Explosive actuated fastening tools

When: Before use and at regular intervals.
What: Inspect the tool to determine that:
• It is clean,
• All moving parts operate freely,
• The barrel is free from obstructions.
Any tool not in proper working order must be immediately removed
from service and repaired in accordance with the manufacturer’s
specifications.
Category: Other Portable Tools and Equipment (1910.244)
When: Dependent upon the service conditions, but not less frequently
than the following:
For jacks used constantly or intermittently at one locality:
Once every six months.
For jacks subjected to abnormal load or shock: Immediately
before and immediately thereafter.
For jacks sent out for special work: When sent out and when
returned.
What: Inspect jack components including (but not limited to):
• Load rating markings,
• Blocking,
• Antifreeze liquid (if used), and
• Lubrication.
Category: Welding - General (1910.252)
When: Before cutting or welding is permitted.
What: An individual responsible for authorizing cutting and welding opera-
tions must inspect the area and designate necessary precautions.
Category: Oxygen-fuel Gas Welding and Cutting (1910.253)
When: Before use.
What: Inspect union nuts and connections on regulators to detect faulty
seats which may cause leakage of gas when the regulators are
attached to the cylinder valves.
Category: Resistance Welding (1910.255)

When: Periodically
What: Qualified maintenance personnel must inspect all equipment,
including (but not limited to) components such as:
• Interlocks,
• Guarding,
• Shields,
• Switches,
• Stop buttons,
• Safety pins,
• Grounding, and
• Ventilation.
• The date;
• A serial number, or other identifier, of the equipment that was
inspected.
Any equipment defects must be reported to his/her supervisor and
the use of the equipment must be discontinued until safety repairs
have been completed.
Category: Pulp, Paper, and Paperboard Mills (1910.261)
Acid towers
When: Monthly.
What: Inspect elevators, runways, stairs, etc. for the acid tower for defects
that may occur because of exposure to acid or corrosive gases.
When: Daily during winter months.

What: Inspect outside elevators for defects when ice materially affects
safety.
Hoops for acid storage tanks

When: Scheduled as determined by the employer.
What: Inspect hoops of tanks for defects to ensure that they are in safe
condition.
Digester
When: As specified under 29 CFR 1910.134, Respiratory Protection.
What: Inspect gas masks used for protection against sulfurous acid and
chlorine gases as specified under 29 CFR 1910.134, Respiratory
Protection.
Recordkeeping: As specified under 29 CFR 1910.134, Respiratory Protection.
When: At least semiannually.

What: Inspect heavy duty pipe, valves, and fittings used between the
digester and blow pit to determine the degree of deterioration.
When: Before each use.

What: Inspect all ladders and lifelines used to enter a digester to conduct
inspections or repair work.
Pressure tanks-accumulators (acid)

When: Twice annually.
What: Inspect pressure tanks-accumulators in accordance with the ASME
Boiler and Pressure Vessel Code, Section VIII, Unfired Pressure
Vessels-1968, with Addenda.
Liquid chlorine tanks

When: Regularly.
What: Inspect gas masks used for protection against chlorine gas as
specified under 29 CFR 1910.134, Respiratory Protection.
Lifting equipment
When: Regularly.
Regularly. Inspect all lifting equipment to ensure that they are in safe condi-
tion.
Category: Bakery Equipment (1910.263)
When: If bakery: At least twice a month.
What: An appointed, properly instructed bakery employee must inspect all
of the safety devices on each oven.
When: If oven manufacturer: At least once a year.

What: A representative of the manufacturer must inspect all of the safety
devices on each oven.
Category: Sawmills (1910.265)
Tramways and trestles
When: Frequently.
What: Inspect mud sills or foundations to ensure they are in good condi-
tion.
Ropes and cables

When: When installed and once a week thereafter when in use.
What: Inspect wire rope and cable components for:
• Kinks,
• Broken wires, and
• Corrosion.
Rope and cables must be removed from service as specified under
29 CFR 1910.265(c)(24)(v).
Chains
When: Before initial use and weekly thereafter.
What: Inspect chains used in load carrying service for stretching.
Any three foot length of chain that has stretched one-third the
length of a link must be discarded.
Stacker and unstacker

When: Frequently.
What: Inspect every stacker and unstacker to ensure that they are in good
condition.
Pond boats and rafts

When: Unspecified.
What: Inspect the bilge area for accumulation of highly combustible mate-
rials.
Band head saws

When: Unspecified.
What: Inspect for:
• Cracks,
• Splits,
• Broken teeth, and
• Other defects.
A crack greater than one-tenth the width of the saw cannot be used
until the width of the saw is reduced to eliminate the crack, until the
cracked section is removed, or crack development is stopped.
Band head saw wheels

When: Monthly.
What: Inspect:
• Hubs,
• Spokes,
• Rims,
• Bolts, and
• Rivets.
The wheel is unfit for service if a loose or damage hub, rim crack,
or loose spokes are found.
Category: Logging Operations (1910.266)
Personal protective equipment
When: Before initial use during each workshift.
What: Inspect equipment, including any provided by an employee, for
defects or damage.
Damaged or defective personal protective equipment must be
repaired or replaced before work is commenced.
Hand and portable powered tools

What: Inspect each tool, including any provided by an employee, for the
following (at a minimum):
• Handles and guards are in place and found, tight-fitting, properly
shaped, and free of splinters and sharp edges;
• Controls properly function;
• Chain-saw chains are properly adjusted;
• Chain-saw mufflers are in place and operational;
• Chain brakes and nose shielding devices are in place and prop-
erly function;
• Heads of shock and impact-driven and driving tools do not
exhibit mushrooming;
• Cutting edges are sharp and properly shaped; and
• All other safety devices are in place and properly function.
Machines
What: Inspect each machine, including any provided by an employee, for
defects or damage.
Damaged or defective machines must be repaired or replaced
before work is commenced.
Vehicles
What: Inspect each vehicle used to perform any logging operation for
defects or damage.
Damaged or defective vehicles must be repaired or replaced
before work is commenced.
Category: Telecommunications (1910.268)
Support structures
When: Before use.
What: A competent person must inspect the support structure of pole
structures, platforms, ladders, walkways or other elevated struc-
ture, or aerial device to determine that it is:
• Adequately strong,
• In good working condition,
• Properly secured in place.
Tools and personal protective equipment

When: Before use each day.
What: A competent person must inspect personal protective equipment,
tools, and devices to determine that they are in good condition.
Personal climbing equipment

What: A competent person must inspect all safety belts and straps to
determine that they are in safe working condition.

What: A competent person must inspect pole climbers for the following
conditions:
• Fractured or cracked gaffs or leg irons,
• Loose or dull gaffs, and
• Broken straps or buckles.
Defective pole climbers must be corrected before use.
Ladders
When: As specified under 29 CFR 1910.25, Portable Wood Ladders;
1910.26, Portable Metal Ladders; and 1910.27, Fixed Ladders.
What: A competent person must inspect ladders for (at a minimum*):
• Strength,
• Condition,
• Proper securement,
• Sharp edges,
• Burrs,
• Decay,
• Corrosion, and
• Cracks.
*Additional inspection parameters are specified under 29 CFR
1910.25, Portable Wood Ladders; 1910.26, Portable Metal Lad-
ders; and 1910.27, Fixed Ladders.
Vehicle-mounted material handling devices and other mechanical

equipment
When: Each day the equipment is to be used.
What: A competent person must inspect equipment to determine that it is
in good condition.
When: At least once a year and by intervals set by the manufacturer.

What: A competent person must inspect derricks and its associated
equipment to determine that it is in good condition.
Recordkeeping: A record of the inspection must be maintained that includes:
• The date;
• Repairs that were made, and
• Corrective actions, if any were required.
Cable suspension strand

When: Before attaching a splicing platform to a cable suspension strand if
the strand passes over electric power wires or railroad tracks.
What: Inspect (from an elevated working position at each pole supporting
the span in question) the strand for the following:
• Corrosion,
• One or more broken wires of the strand,
• Worn spots, and
• Burn marks.
Defective strands may not be used to support any splicing platform,
scaffold, or cable car.
Tree trimming
When: Before climbing, entering, or working around any tree.
What: The employee and the foremen or supervisor in charge must
closely inspect the area to determine whether an electrical power
conductor passes through the tree or within reaching distance of an
employee who will be working in the tree.
Category: Electric Power Generation, Transmission, and Distribution
(1910.269)
General
What: The employer must conduct inspections to determine that each
employee is complying with required safety-related work practices.
First aid
When: At least once a year.
What: Inspect first aid kits to ensure that expended items are replaced.
Lockout/tagout procedures
What: Where lockout is used: An authorized employee, other than the
the procedure and a review of each authorized employee’s respon-
sibilities under the energy control procedure being inspected.
Where tagout is used: An authorized employee, other than the
the procedure and a review of each authorized and affected
employee’s responsibilities under the energy control procedure
being inspected and the following:
• Tags are used only as warning devices and not as a physical
restraint on energy isolating devices that would otherwise require
the use of a lock;
• Tags are not removed without authorization of the authorized
person responsible for it or that it has not been bypassed,
ignored, or otherwise defeated;
• Tags are legible and understandable by all authorized employ-
ees, affected employees, and all other employees who work
operations are or may be in the area;
• Tags and their means of attachment are made of materials which
will withstand the environmental conditions encountered in the
workplace;
• Tags are securely attached to energy isolating devices so that
they cannot be inadvertently or accidentally detached during
use; and
• The meaning of tags is understood by employees as part of the
overall energy control program.
Any deviations or inadequacies found during the inspection must
be corrected.
Recordkeeping: A certification document must be kept of inspections that includes:
• The date;
• The name of the employees included in the inspection;
• The name of the person who performed the inspection; and
• The name, or other identifier, of the machine or equipment on
which the energy control procedure was being utilized.

restored.
What: The authorized employee must inspect the work area to ensure
that nonessential items have been removed and that machine or
equipment components are operationally intact.

What: Inspect body belts, safety straps, lanyards, lifelines, and body har-
nesses to determine that the equipment is in safe working
condition.
Defective equipment may not be used.
Live-line tools
What: Visually inspect each live-line tool for defects.
Mechanical equipment
When: Before use on each workshift.
What: Visually inspect the critical safety components (i.e., those whose
failure would result in a free fall or free rotation of the boom) of
mechanical elevating and rotating equipment to ensure it is in safe
working condition.
Climbing ropes
When: Before each use.
What: Inspect rope for damage or defects.
Damaged and defective rope may not be used.
Underground electrical installations

When: Unspecified.
What: Inspect energized cables that are to be moved for defects.
Water and steam spaces

When: Before work is permitted and after its completion.
What: A designated employee must inspect the conditions in water and
steam spaces associated with boilers.
Boilers
When: Before internal furnace or ash hopper repair work is started.
What: Inspect overhead areas for possible falling objects.
If the hazard of fall objects exists, planking or nets must be pro-
vided as overhead protection.
Recordkeeping: None required
Personal flotation devices

When: Frequently.
What: Inspect each personal flotation device to ensure that is does not
have:
• Rot,
• Mildew,
• Water saturation, or
• Any other condition that could render the device unsuitable for
use.
Wood poles
When: Before it is climbed.
What: A qualified employee should inspect the wood pole for:
• Buckling at the ground line,
• Unusual angle to the ground,
• Cracks,
• Holes,
• Shell rot and decay,
• Knots,
• Depth of setting,
• Soft, wet, or loose soil, and
• Burn marks.
A hammer and/or rocking test may also need to be conducted.
Category: Grain Handling Facilities (1910.272)

Maintenance
When: Regularly.
What: At the least, inspect the mechanical and safety control equipment
associated with dryers, grain stream processing equipment, dust
collection equipment (including filter collectors), and bucket eleva-
tors to ensure it is in safe working condition.
Bucket elevators
When: If less than one million bushel permanent storage capacity
and absent motion detection and alignment monitoring
devices: Daily
What: Visually inspect bucket movement and tracking of the belt.
Category: Electrical - Wiring Design and Protection (1910.304)
When: Before use each day (unless they remain connected once put in
place and are not exposed to damage) or upon relocation.
What: Visually inspect each cord set, attachment cap, plug, and recep-
tacle and any equipment connected by cord and plug (except cord
sets and receptacles which are fixed and not exposed to damage)
for:
• External defects (e.g., deformed or missing pins, insulation dam-
age, etc.); and
• Evidence of possible internal damage.
Damaged and defective equipment may not be used until repaired.
Category: Electrical - Selection and Use of Work Practices (1910.333)
When: Before circuits or equipment are reenergized, even temporarily, as
necessary.
What: A qualified person must visually inspect all tools, electrical jumpers,
shorts, grounds, and other such devices to verify that they have
been removed.
Category: Electrical - Use of Equipment (1910.334)

Portable cord- and plug-connected equipment and extension cords
When: Before use on any shift.
What: Visually inspect equipment and cords for:
• External defects (i.e., loose parts, deformed and missing pins,
damage to the outer jacket or insulation, etc.); and
• Evidence of possible internal damage (i.e., pinches or crushed
outer jacket).
Damaged and defective equipment may not be used until repaired
and tested.
Test instruments and equipment

When: Before the equipment is used.
What: Visually inspect test instruments and equipment and all associated
test leads, cables, power cords, probes, and connectors for exter-
nal defects and damage.
Damaged and defective test instruments and equipment may not
be used until repaired and tested.
Category: Electrical - Safeguards for Personal Protection (1910.335)
When: Periodically.
What: Inspect protective equipment as specified under 29 CFR 1910.137,
Electrical Protective Equipment.
Category: Commercial Diving Operations - Pre-dive Procedures
(1910.421)
When: Prior to each dive.
What: Inspected the breathing gas supply system (including reserve
breathing gas supplies), masks, helmets, thermal protection, and
bell handling mechanism (when appropriate) to ensure safe work-
ing condition.
Category: Commercial Diving Operations - Equipment (1910.430)
When: Regularly.
What: Inspect mufflers on intake and exhaust lines of each decompres-
sion chamber to ensure safe working condition.
Category: Asbestos (Appendix F to 1910.1001, Work Practices and Engi-

neering Controls for Automotive Brake and Clutch Inspection,
Disassembly, Repair, and Assembly - Mandatory)
Enclosure
When: Before work begins.
What: Inspect the enclosure for leaks to ensure that it is closed tightly.

When: Before work begins.
What: Inspect the sleeves and ports through which the work will handle
the brakes and clutch to ensure their integrity.
Category: Inorganic Arsenic (1910.1018)
When: Periodically.
What: Inspect dust collection and ventilation equipment to maintain the
effectiveness of the system
Recordkeeping: A record must be maintained of the last check of effectiveness and
cleaning or maintenance.
Category: Coke Oven Emissions (1910.1029)
Batteries
When: Prior to each charge.
What: Inspect:
• Goosenecks and standpipes,
• Roof carbon build-up,
• Steam aspiration system,
• Steam nozzles and liquor sprays,
• Standpipe caps, and
• Charging holes and lids.
Coking
When: To be determined by the employer.
What: Inspect coking operations to control door emissions to the maxi-
mum extent possible.
Pushing
When: At least weekly and after any green push.
What: Inspect heating flues and associated temperatures to prevent
green pushes.
Emissions
When: Regularly.
What: Inspect:
• All controls (i.e., goosenecks, standpipes, standpipe caps,
charging hold lids and casting, jumper pipes, and air seals);
• Damper system,
• Aspiration system,
• Collector main,
• Heating system, and
• Brickwork.
Repairs must be made as soon as possible.
Respiratory protection
When: As specified under 29 CFR 1910.134, Respiratory Protection.
What: As specified under 29 CFR 1910.134, Respiratory Protection.
Protective clothing and equipment

When: Daily*.
What: Visually inspect* protective helmets (hard hats) purchased after
July 5, 1994 and all components for such things as:
• Dents;
• Cracks;
• Penetration; and
• Damage due to impact, rough treatment, or wear.
*As prescribed in ANSI Z89.1-1986, “American National Standard
for Personnel Protection - Protective Headwear for Industrial
Workers-Requirements,” and incorporated by reference.
Category: Bloodborne Pathogens (1910.1030)
When: Regularly.
What: Inspect all bins, pails, cans, and similar receptacles intended for
reuse for visible contamination.
The items must be cleaned and decontaminated immediately or as
soon as feasible.
HIV and HBV Research labs and production facilities

When: Routinely.
What: Inspect liquid disinfectant traps and high-efficiency particulate air
(HEPA) filters (or filters of equivalent or superior efficiency) on
vacuum lines to ensure proper working condition.
Category: Acrylontrile (1910.1045)
When: Regularly.
What: Inspect operations involving liquid acrylontrile to detect leaks and
spills.
Surfaces must be decontaminated when spills are detected.
Category: Formaldehyde (1910.1048)
When: Regularly.
What: Visually inspect operations involving formaldehyde liquids or gas to
detect leaks and spills.
Leaks must be repaired and spills cleaned up promptly.
Category: Methylenedianiline (1910.1050)
Exposure monitoring
When: Routinely.
What: Inspect employees’ hands, face, and forearms potentially exposed
to methylenedianiline.
If exposure has occurred, the source must be determined and cor-
rective measures implemented.
Housekeeping
When: Regularly.
What: Inspect operations involving liquid or solid methylenedianiline for
leaks, spills, and discharges.
Leaks must be repaired and spills cleaned up promptly.
Category: Ionizing Radiation (1910.1096)
When: Initially.
What: Inspect the signal-generating system to verify that the fabrication
and installation were made in accordance with design plans and
specifications as well as develop a thorough knowledge of the
performance of the system and all components under normal and
hostile conditions.
When: Prior to normal operation.

What: Inspect the signal-generating system to assure reliability and to
demonstrate accuracy and performance.
When: Periodically once the system has been in service.

What: Inspect the signal-generating system to ensure that it is at all times
operating within design limits and capable of the required
response.
Training
Must inspectors have special training?

Unless the individuals conducting the inspection have a well-rounded background in
the safety field, they may need specific training or education pertinent to regulatory
compliance, as well as the areas, equipment, or processes to be inspected. Knowledge
of the tasks being performed, accident history of the work area, specialized equipment
used, etc. will enable the inspector to focus on potential problem areas. This will allow
them to adequately identify unsafe conditions or procedures they may not have oth-
erwise noticed.
L
Table of Contents
Lockout/Tagout ..................................................................................... 1
Contractors ...................................................................................... 1
Definitions ....................................................................................... 1
Lockout ........................................................................................... 2
Locks ............................................................................................. 5
Minor Servicing................................................................................. 6
Periodic Inspections .......................................................................... 7
Procedures ...................................................................................... 8
Recordkeeping ............................................................................... 10
Shift Changes ................................................................................. 11
Tagout........................................................................................... 12
Training ......................................................................................... 13
L–1
Reserved
2–L

Lockout/Tagout
Contractors
Are contractors supposed to use their own lockout procedures?

The standard requires that the employer and the contractor inform each other of their
respective lockout/tagout procedures.
Both should identtify all sources of hazardous energy and the contractor should imple-
ment lockout procedures adequate to control all of them. Aside for making sure the
correct procedures are followed, the host employer must ensure that their employees
comply with any restrictions regarding the contractor’s procedures. For example,
employees should be able to recognize the contractor’s lockout equipment and know
to stay clear of the area where the work is being done.
Definitions
What is an energy isolating device?

OSHA defines an energy isolating device as a mechanical device that physically pre-
vents the transmission or release of energy, including but not limited to the following:
• A manually operated electrical circuit breaker;
• A disconnect switch;
• A manually operated switch by which the conductors of a circuit can be dis-
connected from all ungrounded supply conductors, and, in addition, no pole
can be operated independently; a line valve;
• A block; and
• Any similar device used to block or isolate energy.
Push buttons, selector switches, and other control circuit type devices are not energy
isolating devices.
What is an “authorized employee?”

An “authorized employee” is one who locks out or tags out machines or equipment in
order to perform servicing or maintenance on that machine or equipment. An affected
employee becomes an authorized employee when that employees duties include per-
forming servicing or maintenance.
Lockout/Tagout–1
What is an “affected employee?”

An “affected employee” is one whose job requires him/her to:
• Operate or use a machine or equipment on which servicing or maintenance is
being performed under lockout or tagout, or
• Work in an area where servicing or maintenance is being performed under
lockout or tagout.
What is servicing and maintenance?

OSHA considers servicing and maintenance as workplace activities such as construct-
ing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or
servicing machines or equipment. This includes lubrication, cleaning or unjamming of
machines or equipment, and making adjustments or tool changes where the employee
may be exposed to the unexpected energization or startup of the equipment or release
of hazardous energy.
Lockout
What is “lockout?”
“Lockout” is the placement of a lockout device on an energy isolating device, in accor-
dance with an established procedure, ensuring that the energy isolating device and the
equipment being controlled cannot be operated until the lockout device is removed.
A lockout device is a device that utilizes a positive means such as a lock, either key or
combination type, to hold an energy isolating device in a safe position and prevent the
energizing of a machine or equipment. Included are blank flanges and bolted slip
blinds.
When is lockout required?

The standard covers the servicing and maintenance of machines and equipment in
which the unexpected start-up or the release of stored energy could cause injury to
employees because guards have been removed/bypassed and work is being per-
formed close to moving machine parts. Servicing and maintenance are activities such
as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining
and/or servicing machines or equipment. This includes lubrication, cleaning or
unjamming of machines or equipment, and making adjustments or tool changes.
2–Lockout/Tagout
Lockout is required if these activities take place during normal production where an
employee is required to remove or bypass a guard or place a part of the body into a
point of operation. The standard defines “normal production” as using equipment to
perform it’s intended function. During normal production, machine safeguards are in
place to protect workers.
The only exception is when minor servicing is being performed.
Where must locks and tags be applied on a machine?

The locks and tags are to be applied to a machine’s “energy isolating devices.” These
are mechanical devices that prevent the flow of energy to the machine. OSHA says that
an energy isolating device could be “ amanually operated electrical circuit breaker; a
disconnect switch; a line valve; a block; and any similar device used to block or isolate
energy.”
Examples of what are not energy isolating devices include “push buttons, selector
switches, and other control circuit type devices.” The buttons, switches, and dials on a
machine’s control panel are not energy isolating devices.
Must the entire machine be locked out if only part of it is being serviced?
OSHA’s lockout/tagout standard defines an energy isolating device as “a mechanical
device that physically prevents the transmission or release of energy, including but not
limited to the following: A manually operated electrical circuit breaker; a disconnect
switch; a manually operated switch by which the conductors of a circuit can be dis-
connected from all ungrounded supply conductors, and, in addition, no pole can be
operated independently; a line valve; a block; and any similar device used to block or
isolate energy. Push buttons, selector switches, and other control circuit type devices
are not energy isolating devices.”
The device needs to meet the above definition of an energy isolating device to satisfy
the standard’s requirements. If an employer determines that the device does not meet
the definition, then the energy supply needs to be tracked back to a disconnect switch
or circuit breaker which does meet the definition. An November 10, 1999 Letter of
Interpretation notes that the extent of the lockout procedures would depend on the
employees’ activities and their exposure to the hazards. If the maintenance/repair
activities will not expose employees to a certain hazard from a part of the equipment,
that portion of the equipment would not need to be deenergized. The letter includes the
following:
“Question #1: To what extent must an employer go to secure a hydraulic pump and
220/440 volt electric motor during a lockout? Some pressure usually remains within
hydraulic lines on the hydraulic systems, even when the system is shutdown.
“Reply: The standard provides the flexibility for each employer to develop an energy
control program, as set forth in 1910.147(c)(1), which is suited to the needs of the
particular workplace and the particular types of machines and equipment being main-
tained or serviced. The extent to which an employer must control hazardous energy
Lockout/Tagout–3
depends upon the type of servicing or maintenance work being performed, as well as
the type and magnitude of the energy. For example, a hydraulic pump overhaul or the
removal of a hydraulic line is much different, and requires different energy control
procedures, than working on a piece of equipment that is powered by the hydraulic
system. Also, working on the 220/440 volt, nominal, electrical motor is different than
working on either the hydraulic system or the equipment powered by the hydraulics.
“In some operations, the movement of a simple throw disconnect switch to the “off”
mode is a step sufficient to isolate the machine or equipment from the energy source
as required by 1910.147(d)(3). In other cases, a series of predetermined steps may be
necessary to achieve an orderly shutdown of a machine or piece of equipment in order
to safely perform the servicing or maintenance work. This would be the case for the
hydraulic pump overhaul or hydraulic line maintenance tasks.
“The employer should perform hazardous energy analyses of the workplace equipment
and/or machinery to determine the specific procedures for the control of potentially
hazardous energy when employees are performing servicing and maintenance activi-
ties covered by the standard. This is a prerequisite shutdown preparation step,
described in 1910.147(d)(1), which requires authorized employees to have knowledge
concerning the type and magnitude of the energy, the hazards associated with the
energy to be controlled, and the methods or means to control the energy prior to
shutting off the machine or equipment for servicing and/or maintenance activities.
“Question #2: If an employer secures the system motor (by service panel lockout)
against unauthorized or accidental use and no energy hazards related specifically to
the hydraulic system are known to exist, does OSHA commonly accept this adequate
lockout protection?
“Reply: Yes, but only if all of the provisions of the Lockout/Tagout standard, 1910.147
are met and all hazardous energy sources are effectively controlled. Whether a hydrau-
lic pump and motor is effectively locked or tagged out will have to be determined on a
case-by-case basis by the employer, who is ultimately responsible for the safety of
employees.”
There is nothing from OSHA to indicate that the employeer would need to have a
separate written procedure when the work being done only needs to have a portion of
the equipment locked out, but there is also nothing from OSHA to prohibit this practice
if it is determined that employees would be best protected by having a separate pro-
cedure.
When there is a group of workers, must each person apply their own lock?
When more than one person is doing the servicing and maintenance, the requirement
is that each authorized employee must apply his own lock to the group lockout device,
or group lock box. OSHA wants each individual worker to be protected by his or her own
lock. The easiest way to do this is to use a multi–lock hasp on the energy isolating
device. These hasps typically hold about six locks, so each mechanic can apply a lock
to the hasp.
4–Lockout/Tagout
When the job is more complicated, or when several mechanics are involved, employers
can reduce the number of locks needed by using “operations locks” and a group lock
box. In this commonly used method, the equipment is locked out by applying the
“operations locks” to the machine’s energy isolating devices. The person who applied
the locks then places the keys into a group lock box, and he applies his lock to the lock
box. Each other authorized employee then applies his or her own lock to the lock box.
At this point, no one can unlock the operations locks until all the locks are removed from
the lock box. If this method is used, each authorized employee must still have the
opportunity to verify that the equipment is locked out.
Locks
Must each authorized employee be issued a lock?

The standard does not require that each authorized employee must be issued a lock.
Employers can either issue lockout/tagout devices to each authorized employee, or
maintain a supply and assign or distribute them as needed. This does not mean that all
the locks can be opened with the same key. The employee who applies a lock must
have the assurance that he’s the only person who is able to remove it. If an employer
implements a system where employees may not always use the same lock, procedures
must be in place to control who has the keys to those locks. As a suggestion, a
supervisor could keep the keys to shared locks and check-out/check-in the keys when
authorized employees use them.
Must employees’ names be on locks?

Lockout locks must identify the employee who applied them, and employers have
several options on how to do this. Worker’s names can be engraved on the locks issued
to individuals. If employees share a supply of locks, it is acceptable to attach a durable
plastic tag with the employee’s name written on it to the hasp of the lock as it’s applied
during a lockout procedure. Or the employer can have authorized employees’ names
engraved on small metal tags they can slip onto the hasp when they use a lock. If
stickers are used on the locks to identify employees, procedures should be imple-
mented to ensure names remain legible and the stickers are replaced as needed.
Can a lock be cut off if the person who applied it isn’t there to remove it?
First, the employer must have procedures to:
• Verify that the worker isn’t in the facility,
• Make all reasonable efforts to contact the employee and inform him that his
lock has been removed, and
• Make sure the employee knows that the lock has been removed before he
again starts work at the facility.
Lockout/Tagout–5
To remove the lock, a bolt cutters or master key may be used. OSHA says that it is
acceptable to use a master key if removing the lock is performed under the employer’s
direction and in accordance with the procedures above (these procedures and asso-
ciated training must be outlined in the employer’s energy control program). OSHA says,
“the ‘one person, one lock, one key’ practice is the preferred means and is accepted
across industry lines, but it is not the only method to meet the language of the stan-
dard.”
Can a lock be used for purposes other than lockout?

OSHA says at 1910.147(c)(5)(ii) that “lockout devices and tagout devices...shall not be
used for other purposes... .”
Minor Servicing
What is minor servicing?

Minor servicing involves activities that are part of normal production, machine safe-
guards (including interlocked barrier guards) provide employees with the protection
they need, and equipment does not have to be locked out.
When does the minor servicing exception apply?

The lockout/tagout standard does not apply when minor tool changes and adjustments
and other minor servicing activities that take place during normal production opera-
tions.
The minor servicing must be necessary to allow production to proceed without inter-
ruption. OSHA says that the exception only applies if lockout tagout “would prevent the
machine from economically being used in production.” Also, the minor servicing activity
must be:
• Routine: The activity must be performed as part of a regular procedure,
• Repetitive: It must be repeated during the production process, and
• Integral: The activity must be inherent to the production process.
This exception applies only if each and every one of these elements is met.
As an example, OSHA says that the exception would apply when removing a finished
part from an injection molding machine. “Once the machine has completed a cycle,
opening the interlocked sliding gate guard prevents the machine from beginning
another cycle until the operator repositions the guard.” In fact, OSHA accepts the use
of interlocked barrier guards as protection during minor servicing like clearing minor
jams that occur during normal production operations.
6–Lockout/Tagout
If the exception applies, the machine does not have to be locked out, but workers must
still be protected using machine safeguards.
Very importantly, during normal production lockout/tagout can and does apply under
certain circumstances.
Periodic Inspections
How often must periodic inspections be conducted?

OSHA interprets the inspection requirements to mean that each energy control pro-
cedure must be separately inspected at least annually. Energy control procedures
used less than once a year need to be inspected only when they are used.
How must periodic inspections be conducted?

The inspection must include a review of the procedure with all the authorized employ-
ees who use it, but each of those employees does not need to be observed performing
the procedure as part of the inspection. The inspector must be an authorized employee
other than the ones using the procedure being inspected. That individual must observe
the procedure and talk with the employees implementing it to make certain they under-
stand and follow all the requirements.
The inspection is to include a representative number of employees performing the
procedure (all authorized employees are involved, though). The inspector does have to
review the procedures with each authorized employee who may use that procedure.
Affected employees have to be included in the review if tagout is used instead of
lockout.
These reviews can be done through random audits, conducted as part of plant safety
tours, or scheduled as planned visual observations.
Can I group procedures for inspection purposes?

The employer can group distinct procedures associated with similar machines and
consider the group to be a single procedure for the purpose of inspections. This can be
done if the machines or equipment in the group have the same or similar types of
control measures. Grouping can streamline the inspection process. If procedures are
grouped, the employer can inspect a representative number of employees implement-
ing one procedure within each group. OSHA says this approach is acceptable as long
as the inspection sampling reasonably reflects servicing and maintenance operations
and lockout/tagout practices.
Lockout/Tagout–7
Procedures
What are the steps in a lockout/tagout procedure?

LOTO procedures will include the following steps (always follow the steps in the correct
order):
• Prepare for shutdown — Review the equipment’s energy sources, identify
energy isolating devices, and make sure affected employees have been noti-
fied about the lockout (or tagout).
• Shutdown of machine or equipment — Follow the normal operating proce-
dures to turn off the machine.
• Isolate the machine or equipment — Operate each energy isolating device to
stop the flow of energy to the machine.
• Apply lockout/tagout devices — Apply lock(s) to the energy isolating device(s)
to keep them in the “safe” or “off” position. If tagout is used, apply tags to the
energy isolating devices, and take any additional safety measures, as appli-
cable.
• Release stored energy — For example, drain pressure from lines, insert
blocks to keep elevated parts stable, etc.
• Verify isolation of equipment — Attempt to turn on the machine at its control
panel, check the readings on pressure gauges, etc.
When the repair, servicing, or maintenance work is done:
• Make sure the machine is operationally intact (clear of tools and other mate-
rials, guards are in place, etc.).
• Make sure employees are in safe areas.
• Remove the lock(s) (or tag(s)) that were applied.
• Notify affected employees that the locks (or tag(s)) have been removed before
the equipment is started.
What must be done to “verify” lockout?

“Verification” is the final step in a lockout/tagout procedure. The machine should try to
be started and ran using the operating controls. Also, locks and tags should be checked
to ensure they are attached where they belong and that the energy isolating devices
are in the “off” position. Gauges might also need to be checked or test equipment used
to evaluate temperatures, pressures, or to check for the presence of gases, vapors, or
liquid.
Remember, each authorized employee should verify the lockout if there is more than
one person working on the machine.
8–Lockout/Tagout
Does each individual machine require an individual lockout/tagout procedure?

OSHA expects the employer to develop written energy control procedures for each
machine or piece of equipment. The standards says that under certain conditions, the
procedure “for a particular machine or equipment” does not need to be in writing. The
conditions apply when the machine has a single energy source that completely shuts
down the unit, and that energy source will be locked out during repairs.
OSHA’s typical minimal lockout procedure in the standard’s Appendix A can be used as
a template for writing procedures. Each type of machine must have its own types and
locations of operating controls, energy isolating devices, stored energy, etc. And, each
lockout/tagout procedure needs to have enough machine-specific detail so it is useful
to authorized employees. When OSHA uses the word “specific” to describe the ele-
ments of the procedure, it emphasizes the need for detail. Over-generalization does not
provide enough information to the authorized employees. The amount of detail will
depend upon the complexity of the machine and the information the employees must
know to safely lock it out.
Can the same lockout/tagout procedure be used for a group of machines?

Similar machines (such as those using the same type and magnitude of energy), which
have the same or similar types of controls, and which can be locked or tagged out using
the same procedural steps, can be covered by a single procedure.
Machines and equipment can be grouped into the same procedure if they are all
identified in the scope of the procedure and if they all have the same or similar pro-
cedures for:
• Shutting down, isolating, blocking, securing, and dissipating energy;
• Affixing and removing the lockout or tagout devices; and
• Testing the equipment to verify the effectiveness of the procedures.
For example, an employer may have several power presses and decide to group
die-setting activities into a single lockout procedure. This can be done if the presses
have the same or similar control measures and the same steps are used to control
hazardous energy. But, this single procedure would need enough detail and clarity to
guide a die-setter safely through the steps.
In a woodworking shop, many of the machines (such as table saws, radial arm saws,
or routers) all use the same types of energy, have the same or similar controls for
isolating the machines from the energy source, and use the same procedures to apply
lockout. In this case, a single lockout procedure may be used for this group of wood-
working machines. Be certain to identify all of the machines in the scope of the
procedure.
OSHA also provides an example of when machines can’t be grouped into one proce-
dure. Assume that a single procedure is intended to cover a group of machines and that
part of the procedure requires the use of a start/stop button. But, one of the machines
does not have a start/stop button because it is wired directly to an electronic
Lockout/Tagout–9
on-demand signal. In this example, the single procedure would not provide adequate
instructions for the machine without a start/stop button.
Must lockout/tagout procedures be in writing?

In general, yes. OSHA requires an employer to document lockout/tagout procedures.
A written lockout procedure is not required only when the machine only has one energy
supply that’s easy to identify and lock out. The machine can’t have any potential for
stored energy. Locking that one energy isolating device completely de–energizes the
machine. The authorized employee has to lock out the energy supply, and he has to be
the only person in control of the lock. Aside from this, the work being done can’t create
any hazards for other employees in the area, and there can’t have been any accidents
involving repairs to that machine.
Must lockout/tagout procedures be posted on the machine?

OSHA does not require that the written procedures be posted or in-hand during lockout/
tagout, but employers should ensure that authorized employees can somehow review
them as needed so that the correct procedures are being followed. As a good practice,
some employers mark lockout points on the machine’s energy isolating devices or post
photos of the equipment’s lockout points on the machine.
When must affected employees be “notified” of a lockout/tagout procedure?

OSHA requires at 1910.147(c)(9) that affected employees are to be notified by the
employer (e.g., a supervisor) or authorized employee of the application and removal of
lockout/tagout devices. The notifications are to be given before the controls are applied
and after they are removed from the machine or equipment.
Recordkeeping
Must a log of when lockout/tagout are performed be kept?

The standard does not include any requirement to fill out or keep a log or other record
of lockout/tagout events. If the employer keeps service or maintenance logs as a “best
practice,” it would be up to that employer to establish whatever procedures and record
retention times that best fit the need of the company.
10–Lockout/Tagout
Must periodic inspections be documented?

Periodic inpsections must be documented. The documentation must identify:
1. The machine or equipment on which the energy control procedure was being
utilized,
2. The date of the inspection,
3. The names of the employee(s) included in the inspection, and
4. The name of the person(s) who performed the inspection.
OSHA does not require the record be in any specific format; and therefore, it would be
up to the employer to determine a method that is appropriate for the workplace.
Must lockout/tagout training be documented?

Lockout/tagout training must be documented. The certification of training must include
each employee’s name and the dates of training. Certifications must be updated after
any refresher training.
Shift Changes
How must lockout be continued between shift changes?

To continue lockout during shift changes, the easiest method is for the oncoming
authorized employee to apply his locks before the off-going employee removes his
locks. As with a group lockout procedure, a multi–lock hasp or group lock box can be
used to handle the locks. The goal is the uninterrupted protection for the employees
involved in servicing and maintenace.
Things get more complicated when the off–going employee will leave before workers
on the next shift will arrive. In this situation, the procedure could allow for the off-going
employee to apply a tagout device when he removes his lock. The tag indicates that the
lock was removed, but that the machine is not to be re–energized. The on–coming
employee would verify that the system was still de–energized, and would remove the
interim tag and apply his lock. This would assure continuous protection from one shift
to another.
When tagout is used instead of lockout, the employer could use a tag with space for the
off-going employee to sign off (providing the date and time), and for the on-coming
employee to sign on (also providing the date and time). For their own protection, each
employee would verify that the machine is still de–energized before signing onto the
tag.
Lockout/Tagout–11
Tagout
What is tagout?
Tagout is the placement of a tagout device on an energy isolating device, in accordance
with an established procedure, to indicate that the energy isolating device and the
equipment being controlled may not be operated until the tagout device is removed.
A tagout device is a prominent warning device (e.g., a tag and a means of attachment)
which can be securely fastened to an energy isolating device in accordance with an
established procedure, to indicate that the energy isolating device and the equipment
being controlled may not be operated until the tagout device is removed.
Tagout devices, including their means of attachment, must be substantial enough to
prevent inadvertent or accidental removal. Tagout device attachments must be of a
non-reusable type, attachable by hand, self-locking, and non-releasable with a mini-
mum unlocking strength of no less than 50 pounds. They must have the general design
and basic characteristics of being at least equivalent to a one-piece, all-environment-
tolerant nylon cable tie.
Tagout devices must warn against hazardous conditions if the machine or equipment
is energized and must also include a legend such as the following:
• Do Not Start
• Do Not Open
• Do Not Close
• Do Not Energize
• Do Not Operate
When is tagout required?

OSHA prefers employers use lockout procedures. Whenequipment can be locked out,
employers are expected to use lockout procedures. As such, tagout should only be
used if the energy isolating device is not capable of being locked out.
OSHA does allow tagout to be used even if the equipment will accept lockout. To do
this, employers must be able to demonstrate that their tagout system provides “full
employee protection.” The tagout device must be attached at the same location that the
lockout device would have been attached and additional steps must be taken, as
necessary, to provide a level of safety equivalent to that provided by lockout. OSHA
says to use “additional safety measures such as the removal of an isolating circuit
element, blocking of a controlling switch, opening of an extra disconnecting device, or
the removal of a valve handle.” These steps reduce the likelihood of an unexpected
start-up.
12–Lockout/Tagout
These additional steps must be detailed in the documented tagout procedure for the
affected machine.
Often, tagout is required on older equipment. However, when this equipment is
replaced or major repair, renovation, or modification is made, the energy isolating
devices must be upgraded to accept lockout. Also, whenever new machines or equip-
ment are installed, they must accept lockout.
Training
What training is required for authorized employees?

Authorized employees do servicing, maintenance, and repair operations; and there-
fore, need the most detailed training. Authorized employees must understand the
purpose and function of the energy control program and have the knowledge and skills
required to safely apply, use, and remove lockout/tagout devices. Authorized employ-
ees must be trained to recognize hazardous energy sources and understand:
• The type and magnitude of the energy available in the workplace,
• How to properly control the energy, and
• How to isolate equipment from its energy sources.
What training is required for affected employees?

Affected employees need to be instructed on the purpose and use of energy control
procedures, but do not need to have the same level of training as the mechanics.
What training is required for “other” employees?

The standard says that all “other” employees whose work operations are or may be in
an area where energy control procedures may be utilized must be instructed about the
procedures and the prohibition related to attempting to restart or re-energize equipment
that is locked out or tagged out.
For example, office employees who go into production areas to ask about orders or to
check stock may see lockout/tagout equipment on a machine. In cases such as this,
these workers must have a basic understanding of what lockout/tagout is and that
affected equipment must be left alone.
This instruction can be provided via new employee orientation, an employee handbook,
or safety meetings.
Lockout/Tagout–13
When is refresher training required?

Authorized and affected employees need retraining when a change in job assignments,
machines, or processes presents a new hazard. They need retraining when there is a
change in the procedures and whenever the employer believes they are not following
them or that their knowledge of those procedures is inadequate. OSHA does not
specify what should be included in refresher training, but it must reestablish employee
proficiency and introduce new or revised procedures.
Who can conduct lockout/tagout training?

OSHA does not provide trainer qualifications in the standard. Nonethless, an employer
must ensure that employees are adequately trained. The trainer should be able to
explain how to use lockout/tagout procedures on equipment and be able to answer
workers’ questions about specific procedures.
14–Lockout/Tagout
M/N
Table of Contents
Machine Guarding ................................................................................. 1

Anchoring ........................................................................................ 1
Clearances ...................................................................................... 1
Drill Presses .................................................................................... 2
Emergency Stop Buttons (E-Stops) ...................................................... 3
Grinders .......................................................................................... 4
Point of Operation ............................................................................. 5
Press Brakes ................................................................................... 6
Securement ..................................................................................... 6
Training........................................................................................... 7
M/N–1
Reserved
2–M/N

Machine Guarding
Anchoring
Must equipment such as drill presses be anchored?

OSHA requires at 1910.212(b) that machines that are “designed for a fixed location”
must be “securely anchored” to prevent walking or moving.
While there are no OSHA Letters of Interpretation on the issue, the agency has said
that the general thought is that “machinery designed for a fixed location” refers to large
machinery that is not easy to relocate. While there is no recognized rule of thumb
regarding what is meant by “not easy to relocate,” OSHA has said that employers can
clearly exclude “portable” equipment (i.e., equipment that is designed to be moved
around fairly frequently), except when such portable equipment would move during
operation would need to be secured.
Employers should consult the manufacturer (and/or look to see if the equipment has
mounting brackets, etc.). Also, a hazard assessment should be conducted; if the
machine could move during operation, then it must be secured.
Clearances
What is the minimum distance required between machines to prevent bodily harm?
OSHA does not require a minimum distance between machines. However, the agency
does say in 1910.217(f)(3), regarding mechanical power presses, that “the employer
shall provide clearance between machines so that movement of one operator will not
interfere with the work of another. Ample room for cleaning machines, handling mate-
rial, work pieces, and scrap shall also be provided.” (OSHA has similar wording in its
forging machine area standard, only adding in that the arrangement of machines shall
be such that operators will not stand in aisles, per 1910.30(b)).
Otherwise, it would seem to be a case-by-case situation that depends on factors such
as (but not limited to) the type of equipment, its application, and any additional operator
safety concerns. If having the machinery near another machine poses a hazard, OSHA
would expect measures be put in place to protect workers. The agency could potentially
use the General Duty Clause or perhaps the machine guarding regulations in Subpart
O, “Machinery and Machine Guarding,” to cite an employer.
Also, if the area is an exit access (see 1910.36(g)(2)) or if material handling equipment
has to pass through the area (see 1910.22(b)(1)) then there are specific clearances
that must be met.
Machine Guarding–1
How much space is required between an operator and a machine guard?

Absent a machine-specific regulation, the general OSHA machine guarding require-
ments in 1910.212 would apply. That standard is general in nature and requires, among
other things, that workers must be protected from dangerous parts by “one or more
methods” and that the point of operation must be guarded to prevent the operator from
having any part of his body in the danger zone during the operating cycle. In addition,
the standard requires that revolving drums, barrels, and containers must be guarded by
an enclosure which is interlocked with the drive mechanism, so that the barrel, drum,
or container cannot revolve unless the guard enclosure is in place.
Employers should consider consulting OSHA publications, “Concepts and Techniques
of Machine Safeguarding” and “Safeguarding Equipment and Protecting Employees
from Amputations,” as well as industry standard ANSI B11.19, “ Performance Criteria
for Safeguarding.” There are also safeguarding suppliers/companies that offer scales
based on Table O-10 of the OSHA mechanical power press standard and other stan-
dards (e.g., the “gotcha stick”). These typically deal with maximum allowable guard
openings based on the distance to the hazard.
Drill Presses
What type of guarding is required for the drill bit?

OSHA discusses drill presses in its “Safeguarding Equipment and Protecting Employ-
ees from Amputations” publication. It says, among other things, that for drill presses
workers must be protected from the rotating chuck and swarf that is produced by the
drill bit. Guarding at the point-of-operation is difficult because of the nature of the drilling
press, OSHA says.
However, the publication provides the following primary safeguarding methods as ways
to guard the operator and other employees from rotating parts, flying chips, and cut-
tings:
• Specifically designed shields can be attached to the quill and used to guard
this area. For example, telescopic shielding that retracts as the drill bit con-
tacts the piece or a more universal-type shield can be applied.
• Automatic machines and high-production machines could have enclosures
designed and installed to guard the employee from the entire drilling opera-
tion.
• Install guarding over the motor, belts, and pulleys.
• Install an adjustable guard to cover the unused portion of the bit and chuck
above the material being worked.
Several secondary safeguarding methods are also listed in the publication.
2–Machine Guarding
Emergency Stop Buttons (E-Stops)
Can covers or shrouds be used?

OSHA does not address covers or shrouds on e-stops in the standard. However, in the
absence of clear requirements, the agency can and does cite employers under The
General Duty Clause. OSHA has cited employers for putting shrouds/guards around
emergency stop controls. For example, in an April 1, 2010 General Duty Clause cita-
tion, the agency noted the following:
“Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did
not furnish employment and a place of employment which were free from recognized
hazards that were causing or likely to cause death or serious physical harm to employ-
ees in that employees were exposed to caught-in/laceration hazards...The equipment
emergency stop controls were not readily accessible and in some cases, not easily
identifiable. The emergency stop controls had shrouds/guards around the but-
tons and the background immediately around the pushbuttons was not colored yellow.
A feasible and acceptable abatement would be to ensure...that the background imme-
diately around the pushbuttons is colored yellow, in compliance with industry
recognized guidelines for the design and installation of emergency stop devices, such
as but not limited to: American National Standard Institute (ANSI) B11.18-2006 Safety
Requirements for Machines Processing or Slitting Coiled or Non-Coiled Metal, Sub
Clause 6.3.4.4; American National Standards Institute (ANSI) B11.20 Safety Require-
ments for Integrated Manufacturing Systems; National Fire Protection Association
(NFPA) 79 Electrical Standard for Industrial Machinery, Section 10.7... ” [bold emphasis
added]
How often must e-stops be inspected?

OSHA does not address e-stop inspection or testing. However, in the absence of clear
requirements, the agency can and does cite employers under The General Duty Clause
and has cited employers for failure to ensure that emergency stop buttons functioned
as intended. For example, in an March 22, 2007 General Duty Clause citation, the
agency noted the following:
ees in that employees were exposed to being struck-by and caught-in rotating
parts...the employer failed to provide an emergency stop at the operator control
station...that would stop all motions of the machine that cause a hazardous condition,
eg., rotating parts, belts, gears, and cutting heads. Among other methods, one feasible
and acceptable method to correct this hazard is to ensure that the “stop” and “emer-
gency stop” functions on this machine...Conform to the requirements of the
National Fire Protection Association (NFPA) standard 79; Electrical Standard for Indus-
trial Machinery, 2007 edition; Section 9, “Control Circuits and Control Functions;” and
Section 10, “Operator Interface and Control Devices.”” [bold emphasis added]
Grinders
What is the proper adjustment of a tongue rest?

OSHA requires at 1910.215(b)(9) that the tongue guard on the top side of the grinder
be adjusted to within 1/4-inch of the wheel. In addition, 1910.215(b)(3) discusses
proper exposure angle (90°).
What is the proper adjustment of a work rest?

OSHA requires at 1910.215(a)(4) that the work rest be adjusted to within 1/8-inch of the
wheel.
Are wire wheels the same as abrasive wheels?

There are very detailed machine guarding requirements for abrasive wheel machinery
in 1910.215 depending on the operation and equipment and wheel characteristics.
However, certain types of wheels are excluded from coverage under that standard.
Specifically, OSHA says in (a)(5) that exclused machinery includes “ natural sandstone
wheels and metal, wooden, cloth, or paper discs, having a layer of abrasive on the
surface.”
If an employer’s wheels meet the exclusion above, they would not be covered by
1910.215. Instead, they would be covered in 1910.212, “General Requirements for All
Machines” (1910.212 does not address specific types of equipment and is not as
detailed as 1910.215, but it does require that workers be protected from dangerous
parts by “one or more methods” and that the point of operation must be guarded.).
Do machine guards need to be color-coded?

No. There are no requirements to color machine guards yellow, orange, or any other
color. According to 1910.144(a)(3), yellow shall be the basic color for designating
“caution” and for marking physical hazards such as: striking against, stumbling, falling,
tripping, and “caught in between.” However, this regulation was not meant to state
directly or by implication that all machine guards be painted yellow.
According to the Safety Color Code (ANSI Z535.1-1998), yellow is the basic color for
designating caution and for marking physical hazards such as “caught in between.”
Also, ANSI Z535.1-1998 designates orange as the color for identifying hazardous
machine parts which may crush or otherwise injure, as well as for identifying exposed
parts. Orange also is used to indicate “warning.” Be aware that later editions of ANSI
Z535.1 no longer contain the safety color meanings.
Painting machine guarding yellow, orange, or any color is not required but can encour-
age employees not to remove the guarding unless they are trained and authorized.
Lockout/tagout under 1910.147 may be required when maintenance is performed on
the gears under the guard.
How must emergency stop buttons be marked?

According to 1910.144(a)(1)(iii), emergency stop buttons or electrical switches on
which letters or other markings appear, used for emergency stopping of machinery,
must be red. According to 1910.66, Appendix D, emergency stop buttons must also be
marked “STOP.” OSHA does not require the use of “PUSH” labels on emergency stop
button notifications.
The OSHA regulations do not specifically address the color of the backing of the
emergency stop controls. However, industry standard NFPA 79, “Electrical Standard for
Industrial Machinery,” specifies the backing should be yellow. OSHA has referenced
NFPA 79 when issuing General Duty Clause citations for emergency stop control
design. In fact, the following is from am April 1, 2010 General Duty Clause citation:
ees in that employees were exposed to caught-in/laceration hazards...The equipment
emergency stop controls were not readily accessible and in some cases, not easily
identifiable. The emergency stop controls had shrouds/guards around the buttons and
the background immediately around the pushbuttons was not colored yellow. A feasible
and acceptable abatement would be to ensure...that the background immediately
around the pushbuttons is colored yellow, in compliance with industry recognized
guidelines for the design and installation of emergency stop devices, such as but not
limited to: American National Standard Institute (ANSI) B11.18-2006 Safety Require-
ments for Machines Processing or Slitting Coiled or Non-Coiled Metal, Sub Clause
6.3.4.4; American National Standards Institute (ANSI) B11.20 Safety Requirements for
Integrated Manufacturing Systems; National Fire Protection Association (NFPA) 79
Electrical Standard for Industrial Machinery, Section 10.7...” [bold emphasis added]
Point of Operation
Are there any exceptions to guarding all points of operation?

No. OSHA requires in 1910.212 that workers be protected from dangerous parts by
“one or more methods” and that the point of operation must be guarded.
Press Brakes
What standard covers press brakes?

OSHA covers press brakes in 1910.212, “General Requirements for All Machines,” as
press brakes are specifically excluded from the 1910.217 Mechanical Power Press
standard. OSHA does not provide detailed requirements in 1910.212. However, the
agency does provide additional information in compliance directive, “Guidelines for
Point of Operation Guarding of Power Press Brakes” (CPL 02-01-025).
Securement
Is a special/unique fastener needed to secure a machine guard?

Generally speaking, OSHA requires that guards be securely fastened and not be able
to be inadvertently dislodged or removed. However, it depends on the specific standard
that applies as to what the exact wording is in some cases the OSHA regulation does
not address the issue). One prominent requirement is in 1910.219(m) requiring that
guards on mechanical power transmission being securely fastened.
OSHA does further address this issue in a May 07, 2006 Letter of Interpretation (LOI)
which states “the guards may be fastened by any secure method that prevents the
guard from being inadvertently dislodged or removed, including, but not limited to, such
means as screws, bolts, wing nuts and lock fasteners. OSHA would allow guards that
could be easily removed to allow maintenance or repair activities in the most efficient
manner, provided that the guard can be attached securely in place to protect employ-
ees once the maintenance or repair activities are completed.”
Also, in an August 25, 2006 LOI, OSHA says that “with respect to performance–
oriented machine guarding requirements, guard design and construction must be of
such design and strength to protect workers from the machine hazards. Guards must
be affixed to the machine, where possible, and they may be fastened by any method
(e.g., bolts) that prevents the guard from being inadvertently dislodged or removed.
See 1910.212(a)(2) and 1910.219(m)(1).”
And, in OSHA publication, “Safeguarding Equipment and Protecting Workers from
Amputations,” the agency says the following:
“Guards usually are preferable to other control methods because they are physical
barriers that enclose dangerous machine parts and prevent employee contact with
them. To be effective, guards must be strong and fastened by any secure method
that prevents the guard from being inadvertently dislodged or removed. Guards
typically are designed with screws, bolts and lock fasteners and usually a tool is
necessary to unfasten and remove them. Generally, guards are designed not to
obstruct the operator’s view or to prevent employees from doing a job.” [bold emphasis
added]
Training
What are the training requirements for machine/equipment guarding?

OSHA’s standards on machine guarding do not mandate training requirements other
than those specific to training for mechanical power press operators (see
1910.217(f)(2)) and forging machine operators (see 1910.218(a)(2)(iii)). OSHA does
not have a general standard on machine operation or machine operator training
requirements. Nonetheless, it is a good practice for an employer to ensure that employ-
ees have a thorough knowledge of how to inspect and operate the equipment they use
on the job.
Reserved
Reserved
O–1
Reserved
2–O
P/Q
Table of Contents
Portable Fire Extinguishers .................................................................... 1

Condition......................................................................................... 1
Inspection........................................................................................ 1
Location and Accessibility ................................................................... 3
Powered Industrial Trucks .................................................................. 5
Recordkeeping ................................................................................. 5
Training........................................................................................... 6
Portable Ladders................................................................................... 1
Fall Protection .................................................................................. 1
Inspection........................................................................................ 1
Storage ........................................................................................... 2
Training........................................................................................... 2
Use ................................................................................................ 2
Powered Industrial Trucks...................................................................... 1
Attachments..................................................................................... 1
Battery Charging............................................................................... 1
Inspection........................................................................................ 2
Licensing......................................................................................... 2
Material Handling .............................................................................. 3
Modifications .................................................................................... 3
Operation ........................................................................................ 4
Operator Qualifications ...................................................................... 6
Portable Fire Extinguishers ................................................................. 8
Seat Belts ....................................................................................... 9
Trainer Qualifications ......................................................................... 9
Training ......................................................................................... 11
Types............................................................................................ 13
P/Q–1
Reserved
2–P/Q

Condition
Must fire extinguishers be replaced?

OSHA says that foam extinguishers with soldered brass shells and soda acid extin-
guishers with soldered brass shells must be retired from service. Soda acid (stainless
steel shell) and cartridge operated water and/or antifreeze extinguishers are also obso-
lete. Also, any extinguisher which fails the hydrostatic testing requirements outlined in
1910.157(f)(10) must be retired.
While not adopted by OSHA, NFPA 10, “Standard for Portable Fire Extinguishers,”
states that the following types of fire extinguishers are considered obsolete and are to
be removed from service:
• Soda acid;
• Chemical foam, excluding film-forming agents;
• Vaporizing liquids such as carbon tetrachloride;
• Cartridge-operated water;
• Cartridge-operated loaded stream;
• Copper or brass shell joined by soft solder or rivets;
• Carbon dioxide extinguishers with metal horns;
• Solid charge-type AFFF extinguishers;
• Pressurized water fire extinguishers manufactured prior to 1971;
• Any extinguisher with 4B, 6B, 8B, 12B, and 16B fire ratings; and
• Stored-pressure water extinguishers with fiberglass shells.
Employers should contact their local fire authorities to see if NFPA 10 has been
adopted through local or state code.
Inspection
What does OSHA mean by a monthly “visual” inspection of fire extinguishers?

While OSHA’s portable fire extinguisher regulation at 1910.157(e)(2) does not explain
exactly what “visual inspection” should consist of, a June 27, 1997 Letter of Interpre-
tation says that the intent of the monthly inspection is to provide assurance that the
Portable Fire Extinguishers–1

extinguisher will operate effectively and safely. In addition to being in its designated
place (readily accessible and immediately available), and being pressurized, the extin-
guisher should be observed for other possible defects, such as corrosion, mechanical
damage, the presence of welding, soldering, brazing, or possible tampering.
Must a log be kept of inspections?

OSHA requires at 1910.157(e)(1) that “The employer shall be responsible for the
inspection, maintenance, and testing of all portable fire extinguishers in the workplace.”
Employers must perform both a monthly visual inspection and annual maintenance
check. OSHA only requires, however, that the annual maintenance check be docu-
mented.
Even if not required by OSHA, one way to demonstrate compliance with the required
monthly inspection is to document it. The agency allows employers to use what ever
type of recording system, either paper or electronic, which works for their facility.
Typically, inspections are recorded via a tag attached to each fire extinguisher. Also,
under NFPA 10, “Standard for Portable Fire Extinguishers,” monthly fire extinguisher
inspections are required and states at 6.2.1 that “This inspection shall be noted on a tag
or label attached to the fire extinguisher and shall include the date of the inspection and
the initials of the individual doing the inspection.”
Employers should also check with local fire authorites to determine if a tag is required
under local or state fire code.
What criteria must be used to perform annual maintenance of a fire extinguisher?

OSHA requires in 1910.157(e) that portable fire extinguishers be subjected to an
annual maintenance check. OSHA says at 1910.144(c)(31) that maintenance means
“the performance of services on fire protection equipment and systems to assure that
they will perform as expected in the event of a fire. Maintenance differs from inspection
in that maintenance requires the checking of internal fittings, devices and agent sup-
plies.” However, 1910.157(e)(3) says that, “Stored pressure extinguishers do not
require an internal examination.”
OSHA further says in non-mandatory Appendix A to the standard that the ultimate
responsibility for the inspection, maintenance and testing of portable fire extinguishers
lies with the employer and suggests that they also check with the manufacturer of the
unit that has been purchased and obtain guidelines on inspection, maintenance, and
testing.
Can annual fire extinguisher inspections be done in-house?

The Appendix to 1910.157 indicates that if an employer chooses to perform the inspec-
tion, then the employer must make sure that those who perform the inspection have
been trained to do so and to recognize problem areas. NFPA 10, “Standard for Portable
Fire Extinguishers,” provides guidelines as may the extinguisher manufacturer.
2–Portable Fire Extinguishers

Who can perform the portable fire extinguisher “annual maintenance check” required
under 1910.157(e)(3)?
The OSHA regulation does not specify who is to conduct the check. It would be advis-
able to contact the OSHA local area office for guidance on the qualifications needed.
Also, the manufacturer’s instructions should be followed.
In addition, NFPA 10, “Standard for Portable Fire Extinguishers,” (which OSHA refer-
ences in 1910 Subpart L, Appendix B) may provide useful information. This standard
provides detail about who can inspect and service equipment. It requires, among other
things, that “maintenance, servicing, and recharging shall be performed by trained and
certified persons having available the appropriate servicing manual(s)...”
In addition, it always a good idea to check with the local government fire authority for
any additional requirements.
Location and Accessibility
Where should fire extinguishers be placed within a facility?

OSHA says in 1910.157(d) that “portable fire extinguishers shall be provided for
employee use and selected and distributed based on the classes of anticipated work-
place fires and on the size and degree of hazard which would affect their use.
(2) The employer shall distribute portable fire extinguishers for use by employees on
Class A fires so that the travel distance for employees to any extinguisher is 75 feet
(22.9 m) or less.
(3) The employer may use uniformly spaced standpipe systems or hose stations con-
nected to a sprinkler system installed for emergency use by employees instead of
Class A portable fire extinguishers, provided that such systems meet the respective
requirements of 1910.158 or 1910.159, that they provide total coverage of the area to
be protected, and that employees are trained at least annually in their use.
(4) The employer shall distribute portable fire extinguishers for use by employees on
Class B fires so that the travel distance from the Class B hazard area to any extin-
guisher is 50 feet (15.2 m) or less.
(5) The employer shall distribute portable fire extinguishers used for Class C hazards
on the basis of the appropriate pattern for the existing Class A or Class B hazards.
(6) The employer shall distribute portable fire extinguishers or other containers of Class
D extinguishing agent for use by employees so that the travel distance from the com-
bustible metal working area to any extinguishing agent is 75 feet (22.9 m) or less.
Portable fire extinguishers for Class D hazards are required in those combustible metal
working areas where combustible metal powders, flakes, shavings, or similarly sized
products are generated at least once every two weeks.”

Depending upon the classes of anticipated workplace fires, employers must provide
and distribute fire extinguishers according to the requirements outlined above. If on the
other hand, extinguishers are provided but are not intended for employee use and the
employer has an emergency action plan and a fire prevention plan that meet the
requirements of 1910.38 and 1910.39 respectively, then only the requirements of para-
graphs (e) and (f) of 1910.157 apply, and fire extinguishers do not need to be made
available.
However, fire extinguishers may be required by a local or state building or fire code. As
such, employers need to contact their Fire Marshall or fire inspector for details regard-
ing any applicable requirements. An employer’s liaiblity insurance carrier may also
require that fire extinguishers be available throughout their facility.
How much distance must be maintained around a fire extinguisher?

Neither OSHA or the NFPA provide a specific distance that must be left clear around a
fire extinguisher. At 1910.157(c)(1), OSHA states only that employers shall “mount,
locate and identify (fire extinguishers) so that they are readily accessible to employees
without subjecting the employees to possible injury.” NFPA 10, “Standard for Portable
Fire Extinguishers,” states at 1-6.3 “Fire extinguishers shall be conspicuously located
where they will be readily accessible and immediately available...” and at 1-6.6 “Fire
extinguishers shall not be obstructed...” Also, be aware that state or local requirements
may apply.
If an employer can quickly go to and easily retrieve an extinguisher, OSHA should be
satisfied. However, whether or not there is a “blockage” or “accessibility” issue would be
carefully scrutinized by an OSHA inspector. Most employers keep the floor beneath the
fire extinguisher clear, and will mark that area with tape or floor markings so that
nothing is inadvertently placed there.
At what height must extinguishers be mounted?

OSHA only requires that extinguishers be mounted, located, and identified so that they
are readily accessible. However, NFPA 10, “Standard for Portable Fire Extinguishers,”
states that units weighing 40 lbs. or less be installed such that the top of the unit is not
more than five feet above the floor. For units weighing more than 40 lbs., the top of the
unit should be no more than 3.5 feet above the floor. There should always be at least
four inches between the bottom of the unit and the floor.
Must each fire extinguisher be labeled?

OSHA requires at 1910.157(c)(1) OSHA that employers “mount, locate and identify
(fire extinguishers) so that they are readily accessible to employees...” OSHA provides
no other guidance on signage. However, according to 1910.144, red is the basic color

for identification of fire protection equipment and apparatus. As such, fire extinguisher
signage or other identifiers should be red. Also, employers must comply with state and
local fire code which may dictate more specific requirements regarding markings and
labels.
Must fire extinguishers be mounted and maintained on forklifts?

OSHA does not require employers to equip forklifts with portable fire extinguishers.
However, depending on the hazards present in an area where forklifts travel, OSHA
may have requirements for fire protection in that specific hazardous location which
would include mounting extinguishers on forklifts. Again, it depends upon the area
where the forklift operates.
Also, if the truck manufacturer equips the forklifts with fire extinguishers, the employer
must maintain the extinguishers according to the requirements of 1910.157. If the truck
comes so equipped, the extinguisher cannot be removed permanently from the forklift
without written permission from the manufacturer.
Local or state fire codes may also apply, so employers must check with local authorities
or Fire Marshal.
Recordkeeping
Is there a required format for documenting monthly fire extinguisher inspections?

OSHA has no recordkeeping requirements for monthly inspections, as they do for the
annual maintenance checks. However, maintaining records of the inspections would be
considered a good business practice. The following are considerations for inspection:
• Location in designated place;
• The appropriate type of extinguisher(s) is present;
• No obstruction to access or visibility;
• Operating instructions on nameplate legible and facing outward;
• Safety seals and tamper indicators not broken or missing;
• Fullness determined by weighing or “hefting”;
• Examination for obvious physical damage, corrosion, leakage, or clogged
nozzle;
• Pressure gauge reading or indicator in the operable range or position;

• For wheeled units, condition of tires, wheels, carriage, hose, and nozzle;
• Comprehensive maintenance has been performed in the last 6 years (check
date of the last hydro/comprehensive maintenance or the date unit was
placed in service. Date is usually found on a label on the case);
• Hydrotest has been performed in the last 12 years (check date of the last
hydro or the date unit was place in service. Date is usually found stamped into
the case or on a label on the case); and
• HMIS label in place.
Also, extinguishers commonly have a tag attached to them indicating the routine
inspection history. These should be checked to verify that inspections are being done.
How long must fire extinguisher inspection records be kept?

OSHA says in 1910.157(e)(3) that, “The employer shall record the annual maintenance
date and retain this record for one year after the last entry or the life of the shell,
whichever is less.” OSHA does not require that records of monthly fire extinguisher
inspections be retained. However, as a best practice employers should establish an
associated recordkeeping system to demonstrate compliance with the monthly inspec-
tion requirement.
Training
What training must employees receive to operate a fire extinguisher?

OSHA states in 1910.157(g): “(1) Where the employer has provided portable fire extin-
guishers for employee use in the workplace, the employer shall also provide an
educational program to familiarize employees with the general principles of fire extin-
guisher use and the hazards involved with incipient stage fire fighting.
(2) The employer shall provide the education required in paragraph (g)(1) of this section
upon initial employment and at least annually thereafter.
(3) The employer shall provide employees who have been designated to use fire
fighting equipment as part of an emergency action plan with training in the use of the
appropriate equipment.
(4) The employer shall provide the training required in paragraph (g)(3) of this section
upon initial assignment to the designated group of employees and at least annually
thereafter.”
Based upon the above, if an employer has provided portable fire extinguishers for
employee use in the workplace, then OSHA says an educational program to familiarize
employees with the general principles of fire extinguisher use and the hazards involved
with incipient stage fire fighting must also be provided.

Several options are allowed as follows:

Option 1 – Total evacuation of employees from the workplace immediately when alarm
sounds. No one is authorized to use available portable fire extinguishers. The
employer must establish an emergency action plan, fire prevention plan, and train
employees to evacuate immediately.
Option 2 – Designated employees are authorized to use portable fire extinguishers to
fight fires. All other employees must evacuate workplace immediately when alarm
sounds. he employer must then establish an emergency action plan and annually train
designated employees to use fire extinguishers.
Option 3 – All employees are authorized to use portable fire extinguishers. The
employer must establish an emergency action plan and annually train all employees to
use fire extinguishers using hands-on training.
Option 4 – Extinguishers are provided but not intended for employee use. In this case,
an emergency action plan and fire prevention plan must be established and employees
trained accordingly (hands-on training is not required).
Employers must also satisfy local/state building and fire codes in regard to fire extin-
guishers.
What qualifications must an individual have to conduct fire extinguisher training?

The fire extinguisher standard states only that an employer provide “the education
required...” without further explaining how that should be done. In a January 28, 1982
Letter of Interpretation, OSHA says that “where the employer has provided portable fire
extinguishers for employee use in the workplace, the employer shall also provide an
educational program to familiarize employees with the general principles of fire extin-
guisher use and the hazards involved with incipient stage fire fighting. Hands on
experience using actual fires in a controlled environment is not required in your par-
ticular case.” In other word, it is the employer’s responsibility to ensure that employees
are properly trained for their assigned duties. As a good practice, the person who
provides the training should have sufficient knowledge and experience to teach the
trainees to properly use the necessary equipment and efficiently perform the antici-
pated fire fighting procedures.

Reserved

Portable Ladders
Fall Protection
Is fall protection required when using a ladder?

OSHA does not require fall protection be used when working from a portable ladder in
general industry. However, the agency addresses this issue in a January 13, 2000
Letter of Interpretation (LOI). In the LOI, the agency says that if the user is at risk of
falling from a portable ladder OSHA encourages employers to provide additional fall
protection. There are a number of factors to consider in these situations, including the
height of the ladder, limitations of the fall arrest system to be used, environmental
conditions, etc.
Inspection
Do ladders need to be inspected?

OSHA requires at 1910.25(d)(1)(x) that portable wood ladders be inspected fre-
quently. Likewise, a portable metal ladder must be inspected immediately if it is
involved in any of the situations outlined in 1910.26(c)(2)(vi). Neither of these require-
ments specify an exact interval for inspection (other than immediate). As such, an
employer must determine what inspection frequency is appropriate given the circum-
stances of their work processes, procedures, and environmental factors which may
affect the condition of the ladder.
May a ladder with worn stickers or markings still be used?

OSHA does not require ladders to be marked or stickered with specific information.
However, if a manufacturer’s sticker or markings display important safety information
(e.g., weight limits), a faded and/or worn sticker could create a hazard if a user is
unaware of the recommended conditions of use and/or care instructions.
In addition, in 1910.25, “Portable wood ladders” and 1910.26, “Portable metal ladders,”
OSHA prescribes care and use. If the ladder meets these requirements it may be used.
Portable Ladders–1
Employers should be certain that users adhere to the manufacturer’s recommended

conditions of use and/or care instructions.
Also, consider contacting the manufacturer of the ladder to verify any related safety
information for that particular make and model.
Storage
How must ladders be stored?

Care and use requirements for portable wood and metal ladders are specified in
1910.25(d) and 1910.26(c); however, there are no requirements regarding storage or
securement. However, OSHA publication, “Stairways and Ladders: A Guide to OSHA
rules,” says that all ladders should be secured in areas such as passageways, door-
ways or driveways, or where they can be displaced by workplace activities or traffic to
prevent accidental movement. This is not a requirement, but rather a recommendation
by the agency.
Training
Is ladder safety training required?

OSHA does not require employers to train employees on ladder safety; however,
employees should know how to properly use the equipment required to do their jobs,
including ladders.
Use
What is the correct way to climb a ladder?

OSHA does not currently address this issue. However, the agency does provide guid-
ance in the 2010 proposed walking-working surfaces rule. Specifically, under proposed
1910.23(b)(11), (12), and (13), it states that employers shall ensure that employees:
• Face the ladder when ascending or descending the ladder,
• Use at least one hand to grasp the ladder when progressing up and down the
ladder, and
• Do not carry any object orload that cause cause employees to lose balance
and fall.
2–Portable Ladders
Attachments
Are safety platforms attached to the forks of a forklift considered aerial lifts?
A platform attached to the forks of a forklift would not be considered an aerial lift. OSHA
considers these to be forklifts with personnel platforms attached. While the OSHA
standard does not address using personnel platforms with forklifts, the agency does
require that employers obtain manufacturer’s prior written approval, as this is consid-
ered to be an addition/modification affecting capacity and safe operation. In addition,
fall protection and other measures must be utilized to keep those on personnel plat-
forms safe.
Must a powered industrial truck be marked before adding front-end attachments?

A front-end attachment would generally be an “addition” within the meaning of
1910.178(a)(4) that affects capacity and safe operation. Section 1910.178(a)(5)
assumes that the truck with the attachments will already be, “marked to identify the
attachments and show the approximate weight of the truck and attachment combina-
tion at maximum elevation with load laterally centered.” However, before a non-factory-
installed attachment may be used, the employer must comply both with (a)(4), by
obtaining the truck manufacturer’s written approval, and with (a)(5), by having the truck
appropriately marked.
Battery Charging
Is an eyewash required in battery charging areas?

Ultimately, the employer must decide whether an eyewash or shower is required based
on the specific operations and hazards to which employees are exposed. But, generally
if batteries are charged only—no maintenance is performed, batteries are not removed
from the trucks, and no electrolyte is present in the area—an eyewash or shower is not
needed. However, personal protective equipment must be used where needed.
Powered Industrial Trucks–1

Inspection
How often does a forklift have to be inspected?

OSHA requires that forklift vehicles have to be inspected at least daily, or after each
shift when used around the clock as specified in 1910.178(q)(7).
How long is an employer required to keep forklift daily inspection sheets?

OSHA does not require that forklift inspections be documented. However, using an
inspection checklist, either written or electronic, is a good idea for two reasons:
1. Employers ensure that all essential features of the vehicle are inspected
routinely, and
2. It provides evidence to an OSHA inspector that the vehicles are being
inspected as required by 1910.178(q)(7).
Because daily inspection sheets are not required by OSHA, employers should keep
them according to whichever system works best at their company. Also, as part of a
forklift program, it is a good idea to write a company policy stating the specified duration
for which such records are kept (e.g., “We retain forklift inspection sheets for six
months.”)
Note that some state programs might require retention. For example, in California, the
daily inspection log can be considered a record of a scheduled inspection to identify
unsafe conditions and must be retained for one year under Cal/OSHA regulation
§3203(b).
Licensing
Are operators required to have a valid driver’s license?

OSHA has no requirement that a forklift operator have a valid driver’s license. OSHA
does require that every forklift operator be trained and certified to operate the powered
industrial truck in the workplace, and that the operator’s performance be evaluated on
the provisions of 1910.178(l)(3) every three years. The employer must have a record
documenting that the driver has successfully completed the training. That is the only
operating “license” required by OSHA.
2–Powered Industrial Trucks

Material Handling
May an operator use the blades of a fork truck to push a heavy load with the tips?
If the loads that are being bulldozed result in a hazardous condition because they are
not stable or safely arranged, there would be a violation of OSHA’s requirements at
1910.178(o)(1). This work practice is potentially hazardous for the forklift drivers and for
any pedestrians who may be in the area. The forklifts also are probably not designed
to be used in a bulldozing manner. In addition, 1910.178(l)(3)(i)(M) requires that
employees receive training on any operating instructions, warnings, or precautions
listed in the operator’s manual. If the truck’s manual has warnings against these types
of practices then this must be included in the training program content.
Modifications
Must an employer get permission from the manufacturer to add an attachment to a

forklift?
OSHA requires in 1910.178(a)(4) that employers get the manufacturer’s prior written
approval for modifications and additions that affect capacity and safe operation of a
forklift. Further, 1910.178(a)(5) requires that if the truck is equipped with front-end
attachments other than factory installed attachments, the user must request that the
truck be marked to identify the attachments and show the approximate weight of the
truck and attachment combination at maximum elevation with load laterally centered.
The manufacturer of our forklift is no longer in business. Can it be modified?

In an April 11, 1997 Letter of Interpretation OSHA says that “29 CFR 1910.178(a)(4)
requires that ‘Modifications and additions which affect the capacity and safe operation
shall not be performed by the customer or user without manufacturers prior written
approval. Capacity, operation, and maintenance instruction plates, tags, or decals shall
be changed accordingly.’ In the event that a powered industrial truck manufacturer has
been sold to another company and is no longer in business, the user or customer must
contact the purchasing company to request approval. In the event that the original
powered industrial truck manufacturer is no longer in business and has not been
purchased by another entity, the user or customer would be required to contact a
Qualified Registered Professional Engineer for approval of such modifications and
additions.”

May a backup alarm be disabled?

If the alarm was installed from the factory, then OSHA requires the manufacturer’s prior
written approval for any modifications that could affect capacity or safe operation.
Further, in 1910.178(q)(6) OSHA prohibits altering of parts.
Operation
Do powered industrial trucks have to have backup alarms or warning lights?

OSHA does not have a requirement that forklift vehicles be equipped with a backup
alarm or warning light (although these features are standard on most new equipment).
A forklift must have, at minimum, some type of sound-producing device that an operator
can use at cross aisles and blind intersections where vision is obstructed to warn
pedestrians and other forklift drivers that they are approaching. The “sound-producing
device” mentioned in the Powered Industrial Truck standard is a horn.
Are suicide knobs allowed on the steering wheel of a forklift?

The Powered Industrial Truck standard does not specifically address steering knobs.
However, there is an industry standard that OSHA has often referenced: ANSI/ITSDF
B56.1. This industry standard provides some fairly detailed information on steering
knobs. In short, the ANSI standard does allow for steering knobs if certain criteria are
met, and in some cases steering knobs may even be necessary (e.g., when steering
must be accomplished with one hand). The equipment operating instructions should
also be consulted.
What is a recommended speed for forklifts operating within a manufacturing facility

and warehouse?
OSHA does not have specific speed limits set for the safe operation of a powered
industrial truck. However, in determining what is a safe speed, OSHA would take a
variety of factors into consideration. These factors include, but are not limited to, the
type of truck, the manufacturer’s limitations on the truck, the load being carried,
adequate stopping distances, operating surface conditions, pedestrian traffic, and other
safety issues.
While specific speed limits are not available, OSHA has said it would consider the
totality of the circumstances surrounding the operation of the powered industrial truck
in determining whether safe travel speeds are practiced at a workplace. For additional
assistance in determining safe travel speeds, OSHA says an employer could reference
consensus standards such as ASME B56.1, “ Safety Standard For Low Lift and High
Lift Trucks.” For example, paragraph 4.3.2 of ASME B56.1 contains a stopping distance
formula which may be useful in determining approximate theoretical stopping distances

where certain variables are known. This information, along with other factors, can then
be used to calculate a maximum safe speed.
Otherwise, the OSHA regulation addresses speeds in a few places, in a general man-
ner as follows:
• 1910.178(n)(1) – All traffic regulations shall be observed, including authorized
plant speed limits. A safe distance shall be maintained approximately three
truck lengths from the truck ahead, and the truck shall be kept under control
at all times.
• 1910.178(n)(4) – The driver shall be required to slow down and sound the
horn at cross aisles and other locations where vision is obstructed. If the load
being carried obstructs forward view, the driver shall be required to travel with
the load trailing.
• 1910.178(n)(7) – Grades shall be ascended or descended slowly.
• 1910.178(n)(8) – Under all travel conditions the truck shall be operated at a
speed that will permit it to be brought to a stop in a safe manner.
• 1910.178(n)(10) – The driver shall be required to slow down for wet and
slippery floors.
• 1910.178(n)(15) – While negotiating turns, speed shall be reduced to a safe
level by means of turning the hand steering wheel in a smooth, sweeping
motion. Except when maneuvering at a very low speed, the hand steering
wheel shall be turned at a moderate, even rate.
Can operators wear headphones while operating a forklift?

Although neither OSHA’s occupational noise exposure regulation nor the powered
industrial truck standard address the use of headphones in the workplace, OSHA has
issued Letters of Interpretations that do not recommend the practice. A major concern
for a forklift operator is that the operator will increase the volume of the headphones
high enough to drown out workplace noise. This can result in the operator not hearing
alarms and shouted warnings, as well as exposing him/herself to noise levels that
exceed the OSHA permissible exposure levels.
When are wheel chocks required?

In most cases, commercial motor vehicles (CMV) are no longer required to chock trailer
wheels when parking at loading docks. In an agreement between the Federal Motor
Carrier Safety Administration (FMCSA) and OSHA, authority over CMV parking issues
belongs to the FMCSA. Consequently, OSHA’s wheel chocking requirements in
1910.178(k)(1) and 1910.178(m)(7) of the Powered Industrial Truck standard no longer
apply to commercial motor vehicles.
This applies to any vehicle that:
• Has a gross vehicle weight rating or gross vehicle weight of at least 10,001
pounds, whichever is greater, or

• Is designed or used to transport more than eight passengers (including the

driver) for compensation, or
• Is designed or used to transport more than 15 passengers, including the
driver, and is not used to transport passengers for compensation, or
• Is used in transporting hazardous material in an amount requiring placarding
under DOT regulations.
The FMCSA’s parking brake standard, 49 CFR 393.41(a), requires that every com-
mercial motor vehicle manufactured since March 1990 (with the following four
exceptions) be equipped with a parking brake system adequate to hold the vehicle or
combination under any condition of loading.
However, agricultural commodity trailers, converter dolly, heavy hauler, and pulpwood
trailers must carry and use chocking blocks to prevent movement when parked. Section
393.43(d) also requires that the trailer’s brakes be applied automatically upon break-
away from the towing vehicle and maintained for at least 15 minutes.
In April 2001, OSHA instructed its regional offices that enforcement personnel are not
to cite its wheel chocking requirements at 1910.178(k)(1) or 1910.178(m)(7) with
regard to commercial motor vehicles. OSHA is developing enforcement guidelines for
further clarification.
Operator Qualifications
Is a vision/hearing test required before an employee may operate a forklift?

OSHA’s powered industrial truck standard does not specifically address vision/hearing
requirements for operators. However, even though OSHA doesn’t specifically address
it in the regulation, there are obviously some potential concerns and safety issues and
these need to be evaluated in light of the specific operations. In fact, in an October 20,
1976 (edited 2000) Letter of Interpretation, OSHA says that an employer must deter-
mine if full vision is mandatory for the operations and advises that appropriate medical
personnel be consulted.
And, OSHA has issued other interpretations addressing both visual and hearing
impaired potential forklift operators. In general, OSHA states that it considers physical
impairments on a case-by-case basis. If the employer can show that a physically
impaired employee would be a danger to himself and other employees when operating
equipment such as a forklift, the employer has the right to not allow that employee to
become a forklift operator. If the employer knew this fact, but allowed the employee to
operate the vehicle, OSHA could cite under the General Duty Clause which guarantees
all employees a safe and healthful workplace – free of known hazards.
Additionally, the ANSI/ITSDF B56.1-2005 safety standard for low lift and high lift trucks
states in Section 4.18 “Operator Qualifications” that operators must be qualified as to
visual, auditory, physical, and mental ability to operate the equipment safely.

Ultimately, it is up to each employer (with a physician’s guidance, if necessary) to

determine if an employee can operate the forklift in a safe manner, both for himself and
his coworkers.
Also, aside from OSHA, the Americans with Disabilities Act (ADA) may be involved as
it prohibits employers from discriminating against individuals with disabilities in employ-
ment. ADA-related situations must be handled on a case-by-case basis. Employers
may require as a qualification standard that an individual not pose a “direct threat,” if
this standard is applied to all applicants/employees. However, employers must meet
very specific and stringent requirements under the ADA to establish that such a “direct
threat” exists.
Like OSHA, the ADA requires that, when determining whether an employee can, with
or without reasonable accommodation, perform the essential functions of the job, it is
to be done in regard to a particular individual employee, and not require all employees
who operate a forklift to undergo such evaluation. Such a blanket application may not
be job-related and consistent with business necessity, which is an important consider-
ation in evaluating ADA-related situations.
Would a written exam alone (i.e., without practical operation of the truck) suffice for
the required 3-year operator evaluation?
The “evaluation” of “performance” required by the OSHA standard cannot be met by a
written exam alone. A written exam by itself does not indicate whether the operator is
operating the powered industrial truck safely. In most cases, the person conducting the
evaluation would do two things: first, observe the powered industrial truck operator
during normal operations to determine if the operator is performing safely, and second,
ask pertinent questions to ensure that the operator has the knowledge or experience
needed to operate a truck safely. In some cases, because of the danger or complexity
of the operation, the extent of the change in conditions, or the operator’s need for
additional skills, the evaluation will need to be lengthier and more detailed.
What PPE is needed when driving a forklift?

The personal protective equipment (PPE) that is needed will depend on the specific
hazards. Every situation is unique. For example, if a forklift operator must drive into
noisy areas; hearing protection may be needed. The same applies to safety glasses,
gloves, and other PPE. An employer will need to conduct a hazard assessment to
determine what specific PPE is needed for specific tasks/areas.

What PPE is needed when battery charging?

The PPE that is needed will depend on the specific hazards. Every situation is unique.
For example, if the employee is simply plugging in the battery for a charge, then one set
of PPE might be needed. However, if the employee is servicing the battery, then
additional PPE might be needed. Common PPE for battery charging/changing opera-
tions includes goggles, faceshield, gloves, and an apron. An employer will need to
conduct a hazard assessment to determine what specific PPE is needed for specific
tasks/areas.
Does OSHA require forklifts to have fire extinguishers?

OSHA does not require employers to equip forklifts with portable fire extinguishers.
However, depending on the hazards present in an area where forklifts travel, OSHA
may have requirements for fire protection in that specific hazardous location which
would include mounting extinguishers on forklifts. Again, it depends upon the area
where the forklift operates.
However, if the manufacturer equips its forklifts with fire extinguishers, the employer
must maintain the extinguishers (according to the requirements of 1910.157) and can-
not remove/modify the equipment without written permission from the manufacturer.
There are various usage options and training requirements in 1910.157 regarding
portable fire extinguishers.
Also, the Liquefied Petroleum Gas standard at 1910.110(e)(2) requires that LP-Gas
fueled forklifts comply with NFPA 505-1969, “ Standard for Type Designations, Areas of
Use, Maintenance and Operation of Powered Industrial Trucks.” Although the 1969
edition does not reference fire extinguishers, the 2006 edition addresses their use in
Chapter 9, which states that where either the “authority having jurisdiction” or the end
user requires an industrial truck to be equipped with a portable extinguisher, the loca-
tion of the extinguisher must be in accordance with the truck manufacturer’s
recommendation. The NFPA standard also says that industrial trucks can only be
equipped with portable extinguishers if operators have been trained in their safe opera-
tion and use.
How often does the fire extinguisher on a forklift have to be inspected?

OSHA does not require fire extinguishers on forklifts. However, if they are provided they
must meet the requirements outlined in 1910.157(e), which requires portable fire extin-
guishers to be visually inspected monthly and subjected to a maintenance check
annually.

Seat Belts
Must operators wear a seat belt?

There is no specific regulation that addresses the use of seat belts on forklifts. How-
ever, as explained in OSHA’s October 09, 1996 Seat Belt Policy (corrected in 2007),
employers must require operators of forklifts that are equipped with operator restraint
devices, including seat belts, to use the devices. In addition, OSHA may also cite
employers who do not take advantage of a manufacturer operator restraint system or
seat belt retrofit program. OSHA enforces the seat belt issue under the General Duty
Clause of the OSH Act.
Must powered industrial trucks be retrofitted with seatbelts if they were not manu-
factured with them?
OSHA’s current enforcement policy on the use of seat belts on forklifts is that employers
must require operators of forklifts that are equipped with operator restraint devices,
including seat belts, to use the devices. In addition, OSHA may also cite employers who
do not take advantage of a manufacturer operator restraint system or seat belt retrofit
program. This is all explained in Federal OSHA’s October 09, 1996 Seat Belt Policy
(corrected in 2007).
Trainer Qualifications
Who can train, evaluate, and certify forklift operators?

OSHA requires in 1910.178(l)(2)(iii) that the trainers have the “knowledge, training, and
experience” to train operators and evaluate their competence. The OSHA standard
does not further define this requirement or set any specific certifications. However,
OSHA discusses trainer qualifications in the preamble to the December 1998 final rule
which says:
“OSHA has concluded that the final rule should adopt a performance-oriented approach
to the qualifications of trainers and evaluators. As discussed above under issue 1,
OSHA does not have the resources to evaluate and certify trainers and does not
consider it necessary to do so. Trainers and evaluators with different backgrounds can
achieve the level of ability necessary to teach and evaluate trainees. To meet these
commenters’ concerns, OSHA has eliminated the term “designated person” from the
final rule and has instead described the knowledge, skills, or experience any trainer or
evaluator must have under the standard.”

OSHA also provides additional information in Appendix A of the Compliance Directive

on the forklift training requirements, saying:
“How could an employer determine the qualifications of trainers? An example of
a qualified trainer would be a person who, by possession of a recognized degree,
certificate, or professional standing, or who by knowledge, training and experience, has
demonstrated the ability to train and evaluate powered industrial truck operators.
Can the person providing the training come from outside the company? Yes, the
employer may authorize a trainer from outside the company to conduct the training,
such as a training consultant or a manufacturer’s representative. Nonetheless, the
employer must have evidence that the operators have been trained in the required
program topics. Some employers believe they must use an outside training consultant.
However, an employer may utilize an employee who has the knowledge, training, and
experience to provide training and evaluation.”
And, in training and reference materials on the OSHA website, the agency says:
“ Who should conduct the training? All training and evaluation must be conducted by
persons with the necessary knowledge, training, and experience to train powered
industrial truck operators and evaluate their competence. An example of a qualified
trainer would be a person who, by possession of a recognized degree, certificate, or
professional standing, or who by extensive knowledge, training, and experience has
demonstrated the ability to train and evaluate powered industrial truck operators. There
are many resources available to the employer if he/she chooses not to perform the
training himself. Truck manufacturers, local safety and health safety organizations,
such as the National Safety Council local chapters, private consultants with expertise
in powered industrial trucks, local trade and vocational schools are some available
resources. Various Internet sites are devoted to forklift safety. Private companies who
provide forklift safety training services, including videos and written programs, can be
located on various Internet websites. Most videos can be either leased or purchased.
One important thing to remember is that simply by showing employees a video or
videos on some aspect of forklift safety does not meet the full requirements of the
OSHA standard. Site specific information must be conveyed as well as a method to
evaluate the employee’s acquired knowledge subsequent to the training.
If my employees receive training from an outside consultant, how will I know that
these employees have been adequately trained? Outside qualified training organi-
zations can provide evidence that the employee has successfully completed the
relevant classroom and practical training. However, each employer must ensure that
each powered industrial truck operator is competent to operate a truck safely, as
demonstrated by the successful completion of the training and evaluation.”
In addition, there is a Letter of Interpretation that addresses the “experience” aspect of
the trainer requirements which says:
“A trainer must have the “knowledge, training, and experience” to train others how to
safely operate the powered industrial truck in the employer’s workplace. In general, the
trainer will only have sufficient “experience” if he has the practical skills and judgment
to be able to himself operate the equipment safely under the conditions prevailing in the
employer’s workplace. For example, if the employer uses certain truck attachments and

the trainer has never operated a truck with those attachments, the trainer would not
have the experience necessary to train and evaluate others adequately on the safe use
of those attachments. However, the standard does not require that the trainers operate
a PIT regularly (i.e., outside of their operator training duties) as part of their job function
or responsibility.”
If employees receive forklift training from an outside consultant, how does the
employer know they have been adequately trained?
Outside qualified training organizations can provide evidence that the employee has
successfully completed the relevant classroom and practical training. However, at
1910.178(l)(4)(i) OSHA says that each employer must ensure that each powered indus-
trial truck operator is competent to operate a truck safely, as demonstrated by the
successful completion of an evaluation of training.
In an October 01, 1999 Letter of Interpretation, OSHA says that “as long as the
employer has a reasonable basis to believe that the third-party trainer is qualified and
has a program that meets the requirements of the standard, it can rely on that trainer
to conduct the training and evaluation of employees and can certify that these employ-
ees have been trained. However...the employer may need to provide additional training
on site-specific or truck-specific matters.”
Operators must be trained on the local conditions and hazards prior to operating
powered industrial trucks in the workplace. So while the operator may be competent to
operate the equipment itself, the employer is still responsible for training on work-
related topics, as noted at 1910.178(l)(3)(ii).
Training
Is annual forklift training required?

No. OSHA requires refresher training be conducted in relevant topics when one or more
of the situations outlined in 1910.178(l)(4)(ii)(A)-(E) occur; there is not a set frequency.
These situations are:
• The operator has been observed to operate the vehicle in an unsafe manner;
• The operator has been involved in an accident or near-miss incident;
• The operator has received an evaluation that reveals that the operator is not
operating the truck safely;
• The operator is assigned to drive a different type of truck; or
• A condition in the workplace changes in a manner that could affect safe
operation of the truck.

OSHA does, however, require an evaluation of each powered industrial truck operator’s
performance at least once every three years.
When must powered industrial truck refresher training be given?

The standard does not require any specific frequency of refresher training, but
refresher training must be provided when:
1. The operator has been observed to operate the vehicle in an unsafe manner.
2. The operator has been involved in an accident or near-miss incident.
3. The operator has received an evaluation that reveals that the operator is not
operating the truck safely.
4. The operator is assigned to drive a different type of truck.
5. A condition in the workplace changes in a manner that could affect safety
operation of the truck.
However, OSHA does state that “An evaluation of each powered industrial truck opera-
tor’s performance shall be conducted at least once every three years.”
Do operators need to be trained on the make and model of forklift?

Not necessarily, but employers have to train on each “type” of truck. By “type,” OSHA
is talking about basic differences – a sit-down rider truck vs. a stand-up truck. Or, an
order-picker vs. a pallet jack. OSHA doesn’t intend that employers provide refresher
training because someone starts using the same type of truck made by a different
manufacturer. But, keep in mind that the operator will need instruction on any topics,
such as the truck’s controls, that are different.
Do new employees who have prior experience operating forklifts need training?
OSHA requires that employers train employees prior to operating forklifts. This training
must be worksite- and truck-specific. There is, however, a provision in the OSHA
requirements to avoid duplicate training; but there usually is still the need for some
site-specific training. In addition, OSHA requires each employer to evaluate employees
prior to allowing them to operate forklifts in their facility, regardless of whether they have
prior training with another employer.
Do powered industrial truck training requirements cover powered hand trucks?

Yes, the use of powered hand trucks presents numerous hazards to employees who
operate them and those working in the area where they are used. Therefore, training
is required for powered hand trucks. The OSHA regulation at 1910.178(a)(1) indicates
that the requirements, including those for training, cover motorized hand trucks.

Types
Are golf carts and scooters covered under 1910.178?

OSHA does not have a specific regulation for scooters, golf carts, and other types of
personal conveyances (that aren’t intended to move, push, or pull materials). Most of
these types of equipment are not covered under the OSHA Powered Industrial Truck (or
any other specific) standard. However, OSHA still expects that this equipment to be
used safely and could use the General Duty Clause to hold employers responsible for
maintaining a safe workplace, including training operators on safe use. The equipment
manufacturer’s operating instructions are usually a good resource. In addition, there
are industry/ANSI standards for many types of equipment.
Are skid loaders covered under 1910.178?

Whether skid loaders are covered under 1910.178 depends on whether the equipment
was designed primarily as earthmoving equipment. If it is primarily earthmoving equip-
ment, then 1910.178 does not apply. See the following two OSHA Letters of
Interpretation for additional information:
• October 21, 1999 – Earthmoving equipment is not covered by 1910.178;
skid-steer equipment may be covered
• March 07, 2000 –Applicability of 1910.178 to earth moving equipment and
skid steer loaders

Reserved

R
Table of Contents
Recordkeeping...................................................................................... 1
Audits and Inspections ....................................................................... 1
Bloodborne Pathogens....................................................................... 1
Safety Data Sheets ........................................................................... 2
Respiratory Protection ........................................................................... 1
Administration .................................................................................. 1
Breathing Air Quality.......................................................................... 1
Definitions ....................................................................................... 4
Exposure......................................................................................... 6
Filters, Cartridges, and Canisters ......................................................... 6
Fit .................................................................................................. 7
Fit Testing........................................................................................ 8
Immediately Dangerous to Life and Health (IDLH) ................................. 11
Maintenance and Care ..................................................................... 13
Medical Evaluations ......................................................................... 16
Program ........................................................................................ 22
Recordkeeping ............................................................................... 23
Selection ....................................................................................... 24
Training ......................................................................................... 25
Use .............................................................................................. 29
Voluntary Use ................................................................................. 32
9/13 R–1
Reserved
2–R 9/13
Recordkeeping
Audits and Inspections
Will OSHA ask to see a facility’s self-inspection records during an inspection?

OSHA has never officially stated that they will not use self-audits. However, in a final
policy published in the Federal Register, OSHA stated that the agency will not “rou-
tinely” request to see self-audit reports at the initiation of an inspection, and the agency
will not use self-audit reports as a means of identifying hazards upon which to focus
during an inspection.
OSHA has also stated that where a voluntary self-audit identifies a hazardous condi-
tion, and the employer has corrected the condition prior to the inspection and taken
appropriate steps to prevent recurrence, the Agency will refrain from issuing a citation,
even if the violative condition existed within the six months limitations period during
which OSHA is authorized to issue citations.
OSHA also issued a press release dated October 6, 1999, which confirmed this policy.
What must be contained in an employee medical record?

The medical record includes:
• The name and social security number of the employee;
• A copy of the employee’s hepatitis B vaccination status including the dates of
all the hepatitis B vaccinations and any medical records relative to the employ-
ee’s ability to receive the vaccination;
• Copies of all results of examinations, medical testing, and follow-up proce-
dures;
• Copies of the healthcare professional’s written opinion; and
• Copies of the information provided to the healthcare professional.
Who keeps the medical records?

The employer is responsible for the establishment and maintenance of medical
records. However, these records may be kept off-site at the location of the healthcare
provider. The employer must ensure that the medical records are kept confidential and
9/13 Recordkeeping–1
are not reported or disclosed without the express written consent of the worker, except
as required by the standard or as may be required by law.
How long must medical records be kept?

Medical records must be kept for the duration of employment plus 30 years.
What must be included in a bloodborne pathogen training record?

Bloodborne pathogen training records must contain the dates of the training, the con-
tents or a summary of the training sessions, the names and job titles of all persons
attending the training, and the names and qualifications of the persons conducting the
training.
How long must bloodborne pathogen training records be kept?

Training records must be retained for three years from the training date.
Safety Data Sheets
How long do we need to keep obsolete SDSs?

Under 1910.1200, “Hazard Communication,” an employer does not have to keep SDSs
once the materials are no longer in the facility and employees could no longer be
exposed. In fact, OSHA wants you to get rid of obsolete SDSs so that employees are
not hampered by looking through obsolete material in an emergency.
However, if employers are using SDSs to comply with 1910.1020, “Access to Employee
Exposure and Medical Records,” then they need to be kept for the life of the exposed
employee’s employment, plus thirty years, according to the exposure records require-
ments in 1910.1020(d)(1)(ii). Specifically, the regulation states, “Each employee
exposure record shall be preserved and maintained for at least thirty (30) years, except
that...(d)(1)(ii)(B) safety data sheets and paragraph (c)(5)(iv) records concerning the
identity of a substance or agent need not be retained for any specified period as long
as some record of the identity (chemical name if known) of the substance or agent,
where it was used, and when it was used is retained for at least thirty (30) years...”
Employers do not need to keep SDSs as exposures records. However, if the facility
uses SDSs as part of the exposure records, employers must retain them somewhere
for thirty years. They shouldn’t be kept with active SDSs, however.
2–Recordkeeping 9/13
Administration
May an employer have more than one program administrator?

Yes. Each worksite where respirators are required must have a respiratory program.
However, where there is more than one worksite, there will be a program at each site.
In that circumstance, there may be a program administrator for each program.
What is meant by “appropriate” training or experience?

Training or experience must be extensive enough for the program administrator to fulfill
the minimum requirements. The appropriate training will be dependent on the com-
plexity of their respiratory program needs.
Breathing Air Quality
What must be done to ensure that breathing air is of high purity?

Paragraph (i) of the standard provides references which establish parameters for
breathing air quality. Compressed and liquid oxygen are required to meet the specifi-
cations for breathing air outlined by the United States Pharmacopoeia (USP);
compressed air, at a minimum, is required to meet the specifications outlined in the
ANSI/Compressed Gas Association (CGA) Commodity Specification for Air, G-7.1-
1989 for Grade D breathing air. Cylinders of purchased breathing air must have a
certificate of analysis for purchased breathing air quality obtained through the supplier.
What is adequate air quantity and air flow for atmosphere-supplying respirators?
Compressed air sources must have the capacity to provide an adequate supply of
breathing air. Since each airline respirator requires a minimum of 4-6 cubic feet per
minute (cfm) air, compressed air sources should be sized to provide at least this
amount of air for each respirator at the operating pressure specified for the particular
respirator(s) in use. Proper air flow can then be verified by monitoring airline pressure.
The NIOSH respirator certification process establishes the proper air pressure required
for each particular respirator and airline combination. If the air pressure is within the
9/13 Respiratory Protection–1

proper range, the air flow should also be correct. For this reason, an air pressure gauge
should be installed at the point where the airlines are connected to the air supply
manifold.
What are the minimum specifications for Grade D breathing air?

ANSI/CGA G.7-1 – 1989 specifies the contents of Grade D breathing air as: oxygen
(volume/volume) of 19.5 to 23.5 %; hydrocarbon (condensed) of 5 mg/m of air or less;
carbon monoxide of 10 parts per million (ppm) or less; carbon dioxide of 1,000 ppm or
less; and a lack of a noticeable odor.
When may oxygen in greater concentrations than 23.5 % be used in supplied air
systems?
To avoid the potential for fire and explosions, oxygen in greater concentration than
23.5% may only be used with equipment designed specifically for oxygen service or
distribution.
Are there any restrictions on the placement of compressors supplying breathing air?
Yes. The location of the compressor intake is critical to the purity of air supplied to the
respirator user. The compressor must be located in an area uncontaminated by either
combustion exhaust gases produced by vehicles or the compressor motor itself (if
applicable), or by other gases from plant processes.
What does “suitable” mean with regard to compressors equipped with in-line air-
purifying beds and filters?
The term “suitable” means that the compressor is capable of delivering a continuous
supply of Grade D breathing air. On some compressors, especially those that are
oil-lubricated, in-line sorbent beds and filters will need to be installed and maintained to
ensure Grade D air. To further ensure breathing air quality, the air-purifying sorbent
beds and filters must be changed according to the manufacturers’ instructions. Other
compressors, such as some ambient air movers, may be capable of delivering Grade
D air without the addition of sorbent beds and filters.
Do all air compressors used to supply breathing air have to have a carbon monoxide
alarm?
A compressor that is not oil-lubricated is not required to have an alarm. However, an
employer must ensure that carbon monoxide levels in the breathing air do not exceed
10 ppm. Methods for ensuring that the carbon monoxide level does not exceed 10 ppm
include the placement of the air intake for the compressor in an area known to be free
from contaminants, frequent or continuous monitoring of the breathing air supply, the
use of carbon monoxide filters, or the use of high temperature alarms or shut off
devices where necessary.
2–Respiratory Protection 9/13

For an oil lubricated air compressor, carbon monoxide can be produced where oil
enters into the compression chamber and is partially combusted. Carbon monoxide can
also enter the air intake for the compressor if the intake is not properly located. This
type of compressor must have either a carbon monoxide alarm, high temperature
alarm, or both. If only a high temperature alarm is used then the breathing air must be
tested for the presence of carbon monoxide at intervals sufficient to ensure that carbon
monoxide levels do not exceed 10 ppm.
Is it required for an employer to monitor for the presence of carbon monoxide if an

oil-lubricated compressor equipped with a high temperature alarm or automatic shut-
off device is being used?
Yes, carbon monoxide which enters the compressor due to an improperly located air
intake would not be detected by a high temperature alarm. Also, the location of high
temperature alarms on air compressors can vary and are typically placed to protect the
equipment from damage due to overheating. When the alarm sounds, depends on the
location of the alarm sensor.
How is the presence of carbon monoxide measured?

Common methods of measuring carbon monoxide include the use of chemical detector
tubes or direct reading instruments employing electrochemical sensors. When using a
detector tube to test for the presence of carbon monoxide, either a “grab” sample of the
breathing air may be tested or the air may be sampled directly using a specialized kit
available by several manufacturers. The tube reading error for most low range carbon
monoxide detector tubes ranges from 10 –15 %. Electrochemical sensors can be used
for periodic and continuous monitoring of breathing air for the level of carbon monoxide.
These sensors must be calibrated periodically (typically on a monthly basis) to perform
accurately. The measurement error reported for most electrochemical sensors is 5%.
May the carbon monoxide filters with color-change indicators which convert carbon
monoxide to carbon dioxide be used to detect the presence of carbon monoxide in
breathing air?
No, the color change in the indicator is a warning of the presence of moisture in the
breathing air that is trapped in the filter. Moisture can render the filter ineffective. Thus,
the color-change indicator cannot be used to detect the presence of carbon monoxide.
How often should the breathing air supplied by a compressor be tested for the
presence of carbon monoxide?
The frequency of monitoring will depend on the breathing air system in place, adher-
ence to required maintenance procedures, and the location of the air intake for the
compressor. For example, keeping in mind that a given measurement represents only
that instant in time and must be representative of long-term air quality, periodic moni-
toring may be appropriate in situations where the compressor is well maintained and

the air intake for the compressor is located in an area free from contaminants. In
contrast, continuous monitoring would be warranted for older compressors where oil
blow-by is more likely due to piston ring and cylinder wear, or in situations where rental
compressors are used and/or the maintenance history is not known.
May the same air line couplings be used on both breathing air lines and worksite
airlines used to pneumatically power other industrial equipment?
No, all couplings for breathing air must be incompatible with couplings and outlets for
non-respirable compressed air and other gases used at your workplace. This provision
is intended to prevent the cross-contamination and introduction of hazardous contami-
nants into breathing air lines.
May nitrogen be used to purge or blow out the breathing air lines?
No. To prevent the contamination of breathing air lines with a non-respirable gas, the
standard specifically prohibits the introduction of an asphyxiating substance such as
nitrogen into breathing air lines under any circumstances.
Definitions
What is a respirator?
A respirator is a protective facepiece, hood, or helmet that is designed to protect that
wearer against a variety of harmful airborne agents.
What is an escape respirator?

Escape respirators are designed to be used only in an emergency, and only to escape
from a dangerous area to a safe area. There are several escape respirators on the
market. Many of them use a hood with a neck seal instead of a facepiece. They are
typically designed for one-time use for a short period, usually from 15 minutes to an
hour.
What is meant by “user factors?”

“User factors” are medical conditions that may make usage of particular types of
respirators difficult (e.g., high level of exertion, poor sense of smell, and physical
characteristics such as facial scars that may cause difficulties with fit).

What is meant by “workplace factors?”

“Workplace factors” mean the amount of time the respirator will be worn, dimensions
and configuration of the workspace, temperature and humidity of the work environment,
need for unimpeded vision, need for communication with other workers, need for other
personal protective equipment, and the presence of other contaminants.
What is meant by “conditions of certification?”

Respirators are certified by NIOSH. Conditions of certification means limitations of use
stated by NIOSH that accompany the certification. Parts from other manufacturers or
models cannot be substituted.
Air purifying respirators are certified with limitations that include not using them in
immediately dangerous to life or health (IDLH) conditions and not using them in atmo-
spheres containing less than 19.5% oxygen.
What is meant by “a reasonable estimate of employee exposures?”

Exposures must be characterized through methods that may include actual measure-
ments of exposure at a worksite, exposure data from industry or a supplier, and
calculations of concentration based on amount used (mathematical models).
Data from industry-wide surveys by trade associations may be used as long as they
closely resemble the processes and work conditions as described in the survey. The
standard does not specify how an employer is to make a reasonable estimate, nor does
it require the employer to measure employee exposure (the comprehensive substance-
specific health standards have employee exposure monitoring requirements). Even
with actual measurements of exposure, some estimation is still involved since moni-
toring only determines the exposure on a particular day for a specific employee.
What is meant by “physical form” of air contaminant?

“Physical form” refers to whether the air contaminant is a gas, vapor, mist, fume, or
dust; or some combination. For example, solvents commonly used in paints may be
present as vapors and as mists, and an air purifying respirator would need to provide
protection against both.
What is meant by “chemical state” of an air contaminant?

“Chemical state” refers to its valence state. For example, chromium needs to be iden-
tified by its valence state (or the chemical compound) because chromium VI
compounds have much lower exposure limits than chromium metal, chromium II or
chromium III compounds.

What is meant by “appropriate surveillance?”

This means that employers are required to evaluate workplace conditions routinely so
that they can provide additional respiratory protection or different respiratory protection,
when necessary. By observing respirator use under actual workplace conditions,
employers can note problems such as changes in the fit of a respirator due to protective
equipment or conditions leading to skin irritation. An employer can then make adjust-
ments to ensure that employees continue to receive appropriate respiratory protection.
Exposure
Do estimates of employee exposures have to be made by a credentialed individual?

The standard does not require that the person making the estimate have a particular
credential (e.g., industrial hygienist). Persons trained and experienced in evaluating
respiratory hazards posed by workplace atmospheres are the most competent to evalu-
ate exposure levels.
If an employer cannot identify the contaminant or reasonably estimate employee

exposures, is the employer required to consider the atmosphere to be IDLH?
Yes, unless under worst case assumptions, exposures would not be IDLH. For
example, there may be some information available on air concentrations, but not
enough data to reasonably estimate the actual employee exposures. However, by
making reasonable assumptions about the maximum concentrations that could exist,
the employer may be able to show that IDLH conditions would not occur.
In other situations it may not be feasible to identify all of the air contaminants, but
through information on the process one may be able to determine that IDLH conditions
could not occur.
Filters, Cartridges, and Canisters
Can end of service life indicators (ESLI) be used under all workplace conditions?
ESLIs are NIOSH certified for only a few contaminants. NIOSH tests them under most
conditions of use. Cartridges and canisters equipped with ESLIs can be used only if
they are appropriate for the conditions of the employer’s workplace. An example of a
workplace condition that may adversely affect an ESLI is where a cartridge equipped
with a moisture dependent ESLI is used in an extremely dry atmosphere.

Where can change schedules be obtained?

Data supporting schedules may be available for certain chemicals and respirator car-
tridges through respirator manufacturers and suppliers, industry associations and
chemical manufacturers.
How can an employer develop a change schedule?

Employers must develop cartridge change schedules based on available data or infor-
mation that can be relied upon to ensure cartridges are changed before the end of their
useful service life. Workplace factors such as contaminant concentration, presence of
other contaminants, airflow through the filter, temperature, and humidity must be con-
sidered. Certain chemicals “migrate” through the sorbent in storage. Employees must
be aware of this information as well.
Why must the NIOSH label on filters not be removed, obscured, or defaced while in
service?
The NIOSH label serves several purposes. It ensures selection of appropriate filters for
the contaminants encountered in the workplace and permits the employee using the
respirator to check and confirm that the respirator has the appropriate filters before the
respirator is used. Color coding and labeling allow fellow employees, supervisors, and
the respirator program administrator to readily determine that the employee is using the
appropriate filters.
An employer may adopt whatever procedures are appropriate to ensure that the label
remains on the filter and is not removed, defaced, or obscured during respirator usage.
Fit
Is a respirator still effective if an employee has a beard or moustache?

Tight-fitting facepiece respirators must not be worn by employees who have facial hair
that comes between the sealing surface of the facepiece and the face or that interferes
with valve function. Respirators that do not rely on a tight face seal, such as hoods or
helmets, may be used by bearded individuals.
What can be done if an employee has a very small face and has trouble being fit
tested for a respirator?
Manufactures make several different sizes. Respirators may also vary in size from
manufacturer to manufacturer. Users may be able to get a better fit by trying a respi-
rator made by another manufacturer. In some cases, the use of powered air–purifying
respirators may be appropriate. Employers must help find a suitable respirator.

How is the proper respirator size determined?

Proper respirator size is determined through a fit test. Employees using negative or
positive pressure tight–fitting facepiece respirators must pass an appropriate fit test
using the procedures detailed in the Respiratory Protection Standard.
How often must a seal check be done?

The standard requires the user to perform a user seal check each time a tight-fitting
respirator is put on.
What is required of the respirator user to determine if the respirator is properly

sealed?
The required procedure is described in Appendix B-1 of the standard.
Fit Testing
What is the difference between a fit test and fit factory?

A fit test is used to estimate how well the face piece of the respirator is able to form a
seal with an individual’s face. The “test” consists of procedures specified in Appendix
A of the standard. The fit factor is a number based on the ratio of concentration of
contaminate outside the respirator to the concentration inside the respirator.
Do all tight-fitting respirators which are required by the employer or by OSHA have
to be fit tested?
Yes. Both negative pressure and positive pressure tight-fitting respirators must be fit
tested.
Does a self-contained breathing apparatus (SCBA) require fit testing?

Yes, SCBAs require a fit test. Most workplace use of positive pressure atmosphere-
supplying respirators occurs in high hazard atmospheres where a high degree of
certainty is required that the respirator is maximally effective. Fit testing of tight-fitting
positive pressure facepieces is appropriate to reduce the chance of leakage into the
facepiece.
Do tight-fitting negative pressure respirators that are worn voluntarily require a fit
test?
No, respirators worn when not required by OSHA or the employer do not require a fit
test.

Do loose-fitting respirators require a fit test?

No, loose-fitting respirators do not require a qualitative or quantitative fit test.
Which respirator use requires fit testing?

Fit testing is required when OSHA or the employer requires employees to wear tight-
fitting respirators. The employee must pass a fit test prior to the initial use of the
respirator. Additional fit tests are required whenever the employee reports or the
employer, physician or other licensed health care professional (PLHCP), supervisor, or
program administrator observes changes in the employee’s physical condition that
could affect respirator fit.
If the employee changes to a different fitting facepiece a new fit test is required. An
annual fit test is required after the initial fit test.
When would the fit of a respirator be unacceptable?

A respirator may be unacceptable if it causes irritation or pain to an employee, if the
employee is unable because of discomfort to wear the respirator for the time required,
or if the employee is unable to maintain proper seal.
Can an employer use any method of fit testing?

No. The employer must use one of the OSHA-accepted qualitative, or in some cases
quantitative fit, test protocol. OSHA-accepted protocols are found in Appendix A of the
Respiratory Protection Standard.
Can an employer develop its own fit testing method?

Any new fit testing methods must first meet the acceptance requirements of Section II
of Appendix A before it can be used.
Does a “user seal check” qualify as a fit test?

No, a user seal check is a procedure the employee performs each time they don the
respirator. The purpose of the user seal check is to ensure the respirator is properly
seated to the user’s face. It is not a substitute for a fit test of a particular type, model,
and size of a respirator.
Can a qualitatively fit-tested tight-fitting negative pressure air-purifying respirator be

used in an atmosphere greater than 10 times the permissible exposure limit (PEL)?
No. A qualitatively fit-tested tight fitting negative pressure air-purifying respirator can
only be used in an atmosphere less than or equal to 10 times the PEL.

What negative-pressure respirators may be fit-tested with a qualitative fit test

(QLFT)?
Negative-pressure air purifying respirators that will be worn in concentrations that are
equal to or less than ten times the PEL may be fit-tested using QLFT.
Can QLFT be used to test the fit of a full facepiece negative pressure air purifying
respirator?
The factor that limits the use of QLFT is the concentration of the air contaminant in
which it is being worn. If the full facepiece respirator is only being worn in air contami-
nant concentrations that are equal to or less than ten times the PEL, then QLFT can be
used. However, it cannot be used in air concentrations greater than ten times the PEL
unless it is fit tested using a quantitative fit test (QNFT).
Can employee wear tight-fitting air purifying respirators to concentrations of 100

times the PEL for half facepiece respirators and 500 times the PEL for full facepiece
respirators if they are quantitatively fit-tested?
No. The fit factors of 100 and 500 only define what fit factor is necessary to pass the
fit test. The preamble states that the standard incorporates a safety factor of ten
because protection factors in the workplace tend to be much lower than the fit factors
achieved during fit testing. The use of a safety factor is a standard practice supported
by most experts to offset this limitation. The use of safety factors of ten is recommended
by a number of experts and is included in the ANSI standard for respiratory protection.
What are acceptable fit factors for tight-fitting half facepieces and tight-fitting full
facepieces respirators that are fit tested using QNFT?
The acceptable fit factors are 100 for a half facepiece and 500 for a full facepiece as
prescribed in paragraph (f)(7) of the standard.
Is fit testing required of positive pressure respirators such as SCBAs, powered air
purifying respirators (PAPRs), and supplied air respirators (SARs) ?
Yes. The standard requires fit testing of the facepiece to check for leakage. The stan-
dard allows the employer to conduct the test by using a negative pressure respirator
with a facepiece of the same make, model, and size as the positive pressure facepiece,
or by temporarily converting the facepiece for the positive pressure apparatus to a
negative pressure device and performing the fit test.
Can a tight-fitting PAPR be tested simply by not turning the fan motor on?
Yes. By not turning on the fan motor, a PAPR would be operating in the negative
pressure mode.

Is there a frequency of use below which fit testing would not be required for atmo-
sphere supplying respirators?
The standard’s requirement of annual fit testing applies to emergency response per-
sonnel who wear respirators to protect against hazardous atmospheres. Proper fit is
especially necessary for emergency personnel. These people may only wear the equip-
ment infrequently, but when they do use the equipment, they often use it in very
dangerous atmospheres.
Can a probe hole be drilled in a facepiece to perform QNFT and then the probe hole
be sealed so the facepiece can be used on the respirator?
No. The permanently probed respirator only serves as a surrogate for testing purposes.
A face piece with a probe hole drilled in it cannot be restored to its NIOSH-approved
configuration.
Immediately Dangerous to Life and Health (IDLH)
What is IDLH?
OSHA considers an atmosphere to be IDLH when it poses an immediate threat to life,
could cause irreversible adverse health effects, or could impair an employee’s ability to
escape.
When is an oxygen-deficient atmosphere considered IDLH?

All oxygen-deficient atmospheres (when oxygen is less than 19.5% by volume) are
considered IDLH with one exception. If the employer demonstrates that, under all
foreseeable conditions, the oxygen concentration can be maintained within the ranges
and for the altitudes specified in Table II of the standard, then any atmosphere-
supplying respirator may be used.
For all IDLH entry, how many employees must be located outside an IDLH atmo-
sphere.
Environments containing IDLH atmospheres are frequently well-enough understood
and controlled that a single standby person is adequate. In most fixed workplaces, the
atmosphere is known (i.e., has been well defined either through analysis of monitoring
results or through a process hazard analysis). In many industrial IDLH situations, only
one respirator user is exposed to the IDLH atmosphere at a time, which means that a
single standby person can easily monitor that employee’s status (when needed, the
standard requires more than one employee outside).
Even in situations where more than one respirator user is inside an IDLH atmosphere,
a single standby person can often provide adequate communication and support. For

example, in a small pump room or shed, even though two or three employees may be
inside an IDLH atmosphere performing routine maintenance activities such as chang-
ing pump seals, one standby person can observe and communicate with all of them. In
this type of situation, one standby person is adequate and appropriate, as long as the
employee(s) outside is able to perform an effective rescue.
However, there are instances where more than one standby person is needed. For
example, to clean and paint the interior of a multi-level, multi-portal water tower — a
process that often generates a deadly atmosphere as a result of cleaning solution and
paint solvent vapors — employees often enter the tower through different portals to
work on different levels. In such a situation, there would be a need for good commu-
nications at each entry portal, and more than one standby person would be needed to
maintain adequate communication and accessibility.
What does OSHA require in the situation where the standby person must enter an
IDLH atmosphere to provide emergency rescue?
The employer has flexibility in determining who will respond to such emergency rescue
situations. The employer or authorized designee must be notified before the standby
personnel undertake rescue activity and the employer or designee must then provide
appropriate assistance for the particular situation. The employer must ensure that
before entering an IDLH environment to provide emergency rescue, standby personnel
notifies the employer or the employer’s designee who has been authorized by the
employer to provide necessary assistance that they are about to enter.
As part of the written respirator program’s worksite-specific procedures, the procedures
that standby personnel will follow and whom they specifically need to notify in rescue
situations must be specified. The employer’s emergency response team may provide
the necessary support, or other arrangements may have been made with local
firefighting and emergency rescue personnel.
Must the standby person(s) wait for a backup before beginning rescue operations?
Normally, standby personnel must contact the employer or employer’s designee before
undertaking any rescue activities in an IDLH atmosphere. The employer or authorized
designee must take responsibility for ensuring that rescue operations are carried out
appropriately, that rescuers are provided with proper respiratory equipment, and that
employees are prepared to facilitate rescue attempts through proper preparation. How-
ever, the notification provision does not require standby employees to delay entry as
they attempt to contact the employer or wait indefinitely for their employer or designee
to respond to notification before entering the IDLH atmosphere when employees inside
are in danger of succumbing and standby personnel are appropriately trained and
equipped to provide assistance.
In the majority of cases, however, rescuers should not enter the IDLH environment until
receiving some response to the notification that rescue is necessary (i.e., the employer
or designee should know that the rescuers are entering, and emergency response units
should be on their way to the incident).

Once the employer or designee has been notified the employer or designee who is
authorized to do so must provide the necessary assistance appropriate to the situation.
Such assistance does not always require that additional standby personnel enter the
hazardous atmosphere. In some cases, the appropriate assistance could be, for
example, the provision of emergency medical treatment. If standby employees do need
to enter the hazardous environment to perform rescue operations, however, the
employer must ensure that those rescuers are fully protected.
What equipment must be available for rescue efforts?

Standby personnel must have appropriate equipment to minimize the danger to them-
selves during rescue efforts. They must be equipped with pressure demand or other
positive pressure SCBA, or a pressure demand or other positive pressure supplied-air
respirator with auxiliary SCBA. Retrieval equipment must be used unless its use would
increase the overall risk associated with entry into or rescue from the IDLH environ-
ment. Situations exist in which retrieval lines (e.g., harnesses, wristlets, anklets) may
pose an entanglement problem, especially in areas in which air lines or electrical cords
are present in the work areas in which the IDLH atmosphere occurs. Most of the time,
however, rescue with retrieval equipment is effective, and much safer for the rescuers.
Maintenance and Care
What is the proper way to store a respirator that is used routinely?

Respirators must be stored to protect them from damage, contamination, dust, sunlight,
extreme temperatures, excessive moisture, and damaging chemicals. They must also
be packed or stored to prevent deformation of the facepiece and exhalation valve. A
good method is to place them in individual storage bins. Keep in mind that respirator
facepieces will become distorted and the straps will lose their elasticity if hung on a peg
for a long time.
Storing the respirator in a plastic sealable bag after use is not considered a good
practice. The respirator may be damp after use and sealing prevents drying and
encourages microbial growth. If plastic bags are used, respirators must be allowed to
dry before storage.
When do respirators have to be replaced or repaired?

An employer must replace, repair, or discard a respirator that is not functioning prop-
erly. This applies to the routine replacement of respirators and respirator parts. A
malfunctioning or otherwise defective respirator must be replaced or repaired before
the user returns to the work area. Employees must receive the necessary protection
whenever they are in a respirator use area, and employers must ensure that employees
in the respirator use area are wearing respirators that are in good working order.

Must an employer provide company time to employees to clean and maintain the
respirators assigned for use?
An employer is allowed to choose the cleaning and disinfecting program the best meets
the requirements of the standard and the particular circumstances of the workplace. It
is OSHA policy that if the employer elects to have employees clean their own respira-
tors, the employer must provide the cleaning and disinfecting equipment, supplies, and
facilities, as well as time for the job to be done. Failure to do so would be a violation of
paragraph (h)(1) of the standard.
Who can clean and disinfect respirators?

An employer is allowed to choose the cleaning and disinfecting program the best meets
the requirements of the standard and the particular circumstances of the workplace. In
other words, the employer can have respirators cleaned and repaired in a centralized
type operation where respirators are passed out to employees OR the employer may
require the respirator user to handle all cleaning and respirator maintenance functions.
What ever method the employer chooses, respirator cleaning, disinfection, and repair
activities must be performed by employees who are adequately trained in the proper
respirator care procedures.
How often must a respirator be cleaned and disinfected?

The respirator must be checked and cleaned as often as necessary to ensure that the
respirator continues to function properly. This must be done on a case-by-case basis.
An employer should pay particular attention to where the respirator is stored during
breaks and lunch and the extent to which the respirator is protected between each
wearing, to determine if the respirator is maintained in a sanitary condition. For
example, a respirator worn by employees working in a very dusty environment and left
hanging on a nail in the workplace would need cleaning each time it is donned.
If a respirator is used by more than one person, how often must it be cleaned and
disinfected?
Disposable respirators cannot be disinfected; therefore, can only be assigned to one
person. Disposable respirators must be discarded if they are soiled, physically dam-
aged, or reach the end of their service life. Replaceable filter respirators may be
shared, but must be thoroughly cleaned and disinfected after each use before being
worn by a different person using the procedures in Appendix B–2 of the standard or
equally effective procedures recommended by the manufacturer.
Can alcohol wipes be used to clean the inside of the face pieces of respirators?
Yes, if permitted by the manufacturer of the respirator. Appendix B-2 of the standard
has guidance on appropriate respirator cleaning and disinfecting procedures.

What is meant by “equivalent effectiveness” when comparing cleaning and disinfec-

tion procedures found in Appendix B-2 versus the procedures recommended by the
respirator manufacturer?
“Equivalent effectiveness” simply means that the procedures used must accomplish the
objectives set forth in Appendix B-2 (i.e., must ensure that the respirator is properly
cleaned and disinfected in a manner that prevents damage to the respirator and does
not cause harm to the user).
What constitutes acceptable respirator storage conditions besides what is already

required under the standard?
Questions regarding appropriate storage of respirators (e.g., protection against exces-
sive moisture, extreme temperatures, damaging chemicals, etc.) can best be
addressed by contacting the respirator manufacturer to determine what if any additional
specific recommendations are warranted for the workplace-specific use of the respi-
rator(s).
What constitutes a minimally acceptable inspection of a respirator?

For ALL respirators, an employer must ensure that the following items are included in
the visual inspection:
• A check of respirator function;
• Tightness of connections and the condition of the various parts, including but
not limited to, the face piece, head straps, valves, connecting tube, and car-
tridges, canisters, or filters; and
• A check of the respirator’s elastic parts for pliability and signs of deterioration.
At a minimum, an employer should follow the manufacturer’s instructions that accom-
pany the respirator.
SCBA type respirators require an inspection of the air and oxygen cylinders to assure
that the cylinder pressure is maintained at or above 90% of the manufacturer’s rec-
ommended pressure level and that the regulator and low pressure warning devices
function properly. To assure that both the regulator and low pressure warning devices
function properly the warning device must be activated and heard by the person per-
forming the inspection.
For respirators that are available for emergency use, an employer must certify in
writing, on a tag or label attached to the storage compartment, that an inspection was
performed and include:
• The name (or signature) of the person who made the inspection,
• The findings of the inspection,
• Any remedial action, and
• A serial number or other means of identifying the inspected respirator.

What is meant by “a check of respirator function” dealing with respirator inspection?

OSHA does require that the respirator be physically placed on the employee to ensure
that it is working properly. Visual inspection can detect factors that would interfere with
proper performance (e.g., distortion in shape (often the result of improper storage),
missing or loose components, blockage, and improper connections). Alarms can also
be examined without actually putting the respirator on the employee. In addition, exam-
ining elastic parts for pliability and signs of deterioration can be performed without
wearing the respirator as required in paragraph (h)(3)(ii)(B) of the standard.
What type of inspection is required for emergency escape-only type respirators?

Emergency escape-only respirators must be inspected before being carried into the
workplace for use. These types of respirators (e.g., mouthbit type respirators) are
carried in by the individual worker into the workplace for personal use in an emergency,
and must be inspected for proper condition prior to being carried into the workplace.
How can an employer ensure that respirators that fail an inspection or found to be
defective are removed from service and not used?
An employer could use a tag system where a tag stating “out of service” is placed on
the respirator to help ensure that a defective respirator is not inadvertently used.
What would constitute an “appropriately trained” with regard to performing repairs

or adjustments to respirators?
The use of the term ‘appropriately trained’ refers to an individual who has received
training from the manufacturer or otherwise has demonstrated that he/she has the skills
to return the respirator to its original state of effectiveness.
Can any employee repair the respirator reducing or admission valves?

No. These are two types of valves found in atmosphere-supplying respirators. They are
used in conjunction with the respirator’s regulator to provide the respirator wearer with
proper pressure and flow of air supply. These valves serve such a critical function and
the respirator standard requires that these parts be returned to the manufacturer or
given to an appropriately trained technician for adjustment or repair.
Medical Evaluations
Are seasonal or temporary workers exempt from the requirement for medical evalu-
ations?
No. The frequency and duration of respirator use and the worker’s term of employment,
does not affect the requirement for medical evaluation.

Can a fit test for a respirator be performed before the initial medical evaluation has
been completed?
No. The initial medical evaluation must be conducted prior to fit testing to identify
individuals whose health may be harmed by the limited amount of respirator use asso-
ciated with fit testing.
Are employees who are voluntarily using dust masks (e.g., for employee comfort)
required to have medical evaluations?
No. If an employer has determined that there is no hazard, and dust mask use is
voluntary, then no medical evaluation is required.
Be aware that if an employer allows voluntary use of this type of respirator, then they
must provide the employee with the information contained in Appendix D of the stan-
dard and ensure that such respirator use will not itself create a hazard.
Are medical evaluations required for positive pressure, as well as negative pressure,
respirators?
Yes. Clinical studies show that positive pressure respirator use can harm the employee.
Are physicians the only medical professionals allowed to perform medical evalua-
tions for respirator use?
No. A variety of health care professionals may do this depending on the scope of
practice permitted by the state’s licensing, registration, or certification agencies. Each
employer must check with the state licensing agency to see if other health care pro-
fessionals under their state law can independently perform this evaluation, or must do
so under the direction of a licensed physician.
Who is considered a PLHCP qualified to review the employee medical evaluation

questionnaire?
OSHA requires the PLHCP to be legally permitted to provide the healthcare services
required by paragraph (e) of the standard. It is state law that determines the legal scope
of practice. Licensing rules vary from state to state.
Can an employer choose to let each employee use their own personal physician to
provide a medical evaluation rather than using the employer’s PLHCP?
Yes. This may be a workable system where few employees are involved. The employer
will have to contact each of these PLHCPs and provide them with a copy of the
Respiratory Protection Standard and other required supplemental information, as well
as updates when required. The employer must bear the costs of the evaluation. It is not
acceptable for an employee to use their health insurance for this purpose, unless the
employer pays 100% of the insurance premiums.

Can a nurse who does not meet the qualifications of a PLHCP assess a question-
naire?
A nurse not otherwise qualified to be the PLHCP can perform some tasks, such as
distributing the questionnaire, respond to some questions (e.g., providing advice to
employees on where they can obtain assistance in understanding or reading the ques-
tions), and gathering the completed forms in preparation for delivery to the PLHCP. If
the nurse is working under the direction of a physician (or other PLHCP consistent with
state law) who will perform the final review of the assessment, then this arrangement
is acceptable.
If a PLHCPs scope of practice is limited to questionnaire evaluation or a basic physi-

cal exam, can that PLHCP still be used even though further testing and decision
making may be necessary?
Yes. In some cases where medical issues arise that are beyond the scope of the
PLHCP’s license, the remainder of the evaluation will need to involve a physician or
other authorized health care professional (e.g., conducted under the direction of a
physician).
Does the employer have to use the exact language of the questionnaire in Appendix
C if they choose to evaluate by medical questionnaire?
The language of Part A in Appendix C is mandatory if the employer chooses to medi-
cally evaluate by questionnaire. The employer may choose a medical examination in
lieu of the medical questionnaire.
Does the medical questionnaire have to be administered by a PLHCP?

While the employee must be able to discuss the results of the questionnaire with the
PLHCP, the standard does not specify the qualifications of the individual who admin-
isters the medical questionnaire.
Does the PLHCP have to visit the worksite to perform a medical evaluation?
While it might be helpful for the PLHCP to visit the site, there is no requirement to do
so under the standard. The supplemental information required to be provided to the
PLHCP by the standard is sufficient for that individual to make a valid recommendation
on the employee’s ability to wear a respirator.
May the PLHCP add questions to the questionnaire provided in Appendix C?

Yes. Part B of the questionnaire contains 19 optional questions that may be added. In
addition, the instructions to Part B state that any other questions not listed can be
added.

How does an employer ensure the employee understands the questions on the medi-
cal questionnaire if the employee only speaks and/or reads a language other than
English?
Under these circumstances, the PLHCP can assist the employee in filling out the
questionnaire, with the aid of an employer-provided interpreter. The interpreter need
not be a professional and can be a bilingual employee, family member, or friend who
is fluent in the native language of the person answering the questionnaire. The
employer may also have the questionnaire translated into the appropriate language.
What happens if an employee has difficulty reading or understanding the question-

naire?
The employer must take action to ensure the employee understands the questionnaire.
The employer may have the PLHCP assist the employee in filling out the medical
questionnaire or go directly to a physical examination.
How can an employer ensure the employee understands the medical questionnaire
while still meeting the requirements of confidentiality?
Since the medical questionnaire provided in the standard was designed to be easily
understood, oversight should not generally be necessary. When employees have ques-
tions about the questionnaire, they must be provided with the opportunity to discuss the
questions with the PLHCP.
Why do employees have to answer questions about hearing and vision impairments?
Questions 10 through 15 of Appendix C must only be answered by those who will use
full facepiece or SCBA respirators. The configuration of these respirators can further
reduce hearing and vision. If an employee answers ’yes’ to any of the items in these
questions, a medical exam is required.
Who determines the scope and form of the medical evaluation if an employee gives
a positive response to questions 1 through 8 in Section 2, Part A of the question-
naire?
The PLHCP makes this determination, and is also expected to refer the employee to a
physician if warranted.
If there is a single positive response on the questionnaire, does that automatically

require a face-to-face visit with the PLHCP?
No, the scope of the medical evaluation is left to the discretion and professional judg-
ment of the PLHCP. There may be occasions where all that is needed is clarification of
an issue by telephone.

If an employer chooses to provide physical exams, rather than use the questionnaire,
what information must be obtained?
An employer who chooses to skip the questionnaire, and instead go directly to an exam
must ensure that the exam obtains the same information as is found in the question-
naire.
Can an employee decline to be medically evaluated for the use of a respirator?

The standard requires the employer to provide a medical evaluation to an employee
before the employee uses a respirator in the work place; therefore, an employee cannot
refuse to undergo medical evaluation and continue to use a respirator.
Who pays for the medical evaluation and any subsequent exams?
The employer must pay for the medical evaluation and any related expenses incurred
by the employee during the evaluation, including travel costs.
What procedures should be used to maintain confidentiality if the questionnaire is

administered by the employer?
The directions to the employee for answering the medical questionnaire state that the
employer must not look at or review their answers. The employee must be instructed
on how to deliver or send the completed questionnaire to the PLHCP who will review
it. One method for accomplishing this task is for the employer to provide the employee
with a stamped envelope addressed to the PLHCP at the time the questionnaire is
administered.
If the PLHCP discovers that the employee uses drugs, does the PLHCP have an
obligation to tell the employer?
No. The PLHCP must maintain strict confidentiality on specific medical findings unre-
lated to the ability to wear a respirator. Information regarding pregnancy, genetic
susceptibility, mental health problems, and drug use are not to be revealed to the
employer when they result from the medical evaluation process. These findings must
remain confidential. How specific medical information is addressed between the
employee and PLHCP should be determined by the legal, professional, and ethical
standards that govern the PLHCP’s practice.
Why does supplemental information need to be provided to the PLHCP?

When evaluating an employee’s medical limitations, the PLHCP may need to consider
other workplace variables that may increase pulmonary and cardiovascular stress
during respirator use.

How often must supplemental information be provided to the PLHCP?

It need only be provided once, unless there are changes in the supplemental informa-
tion; in that case updated information must be provided to the PLHCP. If an employer
changes PLHCPs, then you must assure that all the information has been transferred
or that new documents are provided to the new PLHCP.
Why is there no specific requirement to give the PLHCP a list of substances the
employee may be exposed to?
The company’s written respiratory program must specify the exposure conditions that
require the use of a respirator. A copy of the written program must be provided to the
PLHCP. The program will provide the necessary information to the PLHCP without
imposing an additional paperwork burden on employers.
Who is responsible for determining an employee’s ability to use a respirator?

The responsibility rests with the employer. The PLHCP’s opinion regarding the employ-
ee’s medical ability to wear a respirator is an important element in making the final
determination. This opinion must be in writing and provided to the employee.
How does the PLHCP’s opinion affect periodic medical evaluation?

The final standard does not automatically require periodic medical re-evaluation. It is
critical, however, that the PLHCP address this issue in their medical opinion. If there is
an underlying medical concern that requires periodic medical reevaluation, it must be
included in the written medical opinion so that the employee can be monitored in the
future by the PLHCP.
Does an employer have to medically re-evaluate the employee’s ability to wear a

respirator on an annual basis?
No. There is no annual or periodic requirement for medical re-evaluation. The standard
lists four conditions that trigger medical re-evaluation as follows:
1. An employee reports signs or symptoms related to the ability to wear a res-
pirator;
2. The PLHCP, administrator, or supervisor determine it is necessary;
3. Information from the respiratory protection program indicates a need for
re-evaluation; or
4. A change in workplace conditions substantially increases the physiological
burden placed on the employee.

Program
Do employers need a written respiratory protection program?

All the worksite specific procedures and elements for required respirator use applicable
to the particular worksite must be in writing. However, paragraph (c)(2)(ii) of the stan-
dard makes clear that the written program need not address those employees who are
not required to use respirators, but who voluntarily wear filtering facepiece respirators.
Does an employer with multiple worksites have the flexibility to develop a generic
written program that would be applicable to all facilities?
Yes. The employer may have different sites with very similar operations, where a
generic or single corporate program could be used. It must, however, include site-
specific provisions to reflect different site conditions.
How frequently should the written respiratory protection program be updated?

The standard requires that employers revise the program as necessary to reflect
changes in the workplace or in respirator use. The written program must be updated
whenever the change occurs. Changes would include different respirator choices,
changes in fit testing, and work operations that change.
Is a written program required if an employer requires respirators to be worn even

though employees are not exposed to airborne contaminants in excess of the per-
missible exposure limit?
Yes. Employer-required use triggers a full respirator program covering all the elements
required under the standard.
How often should the respiratory protection program be evaluated?

OSHA does not have a required interval. Employers must review the written program
and revise, as necessary, the written program elements specified in paragraph (c)(1)
when workplace conditions affecting the use of respirators change. Evaluation fre-
quency is to be based on program complexity and on factors such as the nature and
extent of workplace hazards, types of respirators in use, variability of workplace pro-
cesses and operations, number of respirator users, and worker experience in the use
of respirators. The employer must review respirator use in the workplace with sufficient
frequency to ensure that continuous, successful implementation of all written respirator
program elements prescribed under the standard are being achieved.

What must be re-evaluated?

The areas to be re-evaluated include:
• Whether the respirator program is achieving proper respirator fit,
• Whether the appropriate respirators are being selected, and
• The proper use and maintenance of respirators.
If respirators are not being used properly, the employer is required to correct any
problems found during the assessment.
What type of information should be obtained from employees during a re-evaluation?

The type of information would include:
• Difficulty with breathing or fatigue during respirator use;
• Whether the respirator interferes with hearing, vision, communication, or job
performance or restricts movement;
• Whether the respirator causes discomfort; and
• Whether the employee has confidence in the respirator’s effectiveness.
An employer must correct any problems that are revealed by the evaluation.
Is the presence of medical conditions part of the program evaluation?

Identification of respirator-related medical conditions (e.g., skin irritation) should be part
of the program evaluation. Employees identified during the evaluation as having skin
irritation can either be referred to the PLHCP or be advised by the program adminis-
trator about the need to leave the respirator use area as necessary to wash the face
and face piece, as permitted under the standard. It should be noted that paragraph
(e)(7)(iii) of the standard requires medical evaluation if observations made during the
program evaluation indicate that such evaluation is necessary.
Recordkeeping
Can the employer maintain a copy of an employee’s completed medical question-

naire?
No. The employer must maintain only the PLHCP’s written recommendation on an
employee’s eligibility to wear a respirator. The completed questionnaire and PLHCP’s
documented findings or diagnosis are confidential and must not be maintained by the
employer. An exception is made when the employer’s health office is administratively
separate from the employer’s central administration offices.

How can the employee obtain a copy of their medical evaluation or the medical
questionnaire?
The employer is required to provide a copy of the written opinion to the employee. The
written opinion should be provided by the PLHCP but can be provided by the employer.
Requests for copies of the questionnaire should be made to the PLHCP consistent with
the requirements of 29 CFR 1910.1020, “Access to Employee Exposure and Medical
Records.”
Must the tags that contain the signature of the person authorized to change the inline
sorbent beds and filters on compressors be kept for a specified period of time?
No, only the tag containing the most recent change must be kept at the compressor.
Selection
Can any respirator be used?

No, respirators must be selected on the basis of hazards to which the worker is
exposed (i.e., particulates, vapors, oxygen–deficiency, or combination). Also, OSHA
requires the use of certified respirators.
How can an employer determine if the mass median aerodynamic diameter (MMAD)
of a contaminant is less than 2 micrometers?
Ranges of MMAD for various processes have been reported in published articles. It
also is possible to determine ranges through testing. If the MMAD cannot be deter-
mined, a HEPA filter, or a filter certified for particulates by NIOSH under 42 CFR part
84 (N95 or higher) must be selected.
How many respirator models and sizes are sufficient?

The requirement of the standard is performance-based; therefore, the numbers of
models and sizes must be sufficient to provide a range of sizes and configurations so
that all users can achieve acceptable fits.
Is an employer required to have personal monitoring data when selecting a respira-

tor?
While personal exposure monitoring is the most reliable approach for assessing the
level of respiratory protection required, it may not always be necessary to take personal
exposure measurements to determine whether (or what level of) respiratory protection
is needed. Appropriate safety factors should be used when using estimates of
employee exposures.

Does an employer need to consider emergency situations when selecting respira-

tors?
Yes. When selecting respirators for non-IDLH routine use, an employer must consider
additional problems related to reasonably foreseeable emergency situations.
In addition, there are substance-specific standards (e.g., asbestos) and other stan-
dards (e.g., HAZWOPER) that have requirements to be followed in the event of an
emergency.
Can any supplied air respirator be used for entry into IDLH atmospheres?
No. Paragraph (d)(2)(i) requires a full facepiece pressure-demand SCBA certified by
NIOSH for a minimum service life of thirty minutes or a combination full facepiece
pressure-demand supplied-air respirator with auxiliary self-contained air supply.
Are N95 filters allowed for contaminants with permissible exposure limits below 0.05
mg/m?
Yes, if oil aerosols are not present, and there are no applicable OSHA standards
requiring the use of HEPA filters. If filters are chosen from among those certified under
30 CFR Part 11, which carry the designation TC 21C-xxxx, only HEPA filters can be
used.
Does an employer have to provide a PAPR to an employee who can’t wear a negative
pressure respirator?
An employer must provide a PAPR if the PLHCP determines that the use of a negative
pressure respirator would place the employee at increased risk for adverse health
effects, and the PLHCP finds that the employee can use a PAPR. If a subsequent
medical evaluation finds that the employee is able to use a negative pressure respi-
rator, a PAPR need no longer be provided.
Training
Must the annual retraining be a full retraining exercise?

The annual retraining must address each element required by the standard. Emphasis
in the training elements can vary based on the need of the worksite and knowledge of
the workers.

Is a specific format or method of training required?

An employer may use whatever training format or method is effective for the particular
worksite provided it addresses the required topics. As such, audiovisual and slide
presentations, classroom discussion, informal discussions during safety meetings, etc.,
or a combination of these methods may be used.
Can computer-based training be used?

Yes; however, an employer must ensure that training is conducted in a manner that is
understandable to the employee.
How can an employer ensure that the employee demonstrates an understanding of

the information communicated during training?
An employer can ask the employee, either in writing or orally, about the required
information and observe the employee’s hands-on use of respirators. Written docu-
mentation is not required, but is considered a best practice.
What information must be conveyed to employees about why a respirator is neces-

sary?
The type of information involved would include the nature, extent, and effects of the
respiratory hazards. This includes identification of the hazardous chemicals involved,
what contaminant levels the employee would breathe if no respiratory protection were
used, and what the potential health effects of that exposure would be.
What information must be covered regarding the limitations and the capabilities of
the respirator?
The limitations and capabilities of the respirator would cover how the respirator oper-
ates. This includes an explanation of how the respirator provides protection by filtering
the air, absorbing the vapor, or providing clean air from an uncontaminated source.
Where appropriate, it should also include limitations on the equipment such as prohi-
bitions against using air-purifying respirators in case of an emergency in IDLH
atmosphere, and an explanation of why they should not be used in such situations.
What type of information must be provided concerning respirator use in emergency

situations?
The training program must discuss different emergency situations as appropriate to the
facility such as respirator malfunctions, changes in work routines, and emergency
situations that require the use of a different respirator.

What must employees know about how to inspect and check respirators?
This would include the steps that employees are to follow if they discover any problems
during the inspection (i.e., to whom they should report problems and where they can
obtain replacement equipment if necessary). If an employer routinely has extensive
inspections done by separate personnel. then the standard does not require that indi-
vidual respirator wearers be trained how to do full inspections. Training the employees
in only those parts of the inspection process that they are expected to do is sufficient.
The training must also include the procedures for donning and removing the respirator,
checking the fit and seals, and using the respirator.
Employees must be trained in how to check the respirator seal. Employers must train
employees in the methods set forth in Appendix B or in alternative methods that are
equally effective.
How extensively must the employees be trained about the maintenance and storage
of respirators?
Where employees perform some or all respirator maintenance and store respirators
while not in use, detailed training in maintenance and storage procedures may be
necessary. In other facilities, where specific personnel or central repair facilities are
assigned to perform these activities, most employees may need only to be informed of
the maintenance and storage procedures without having to learn significant technical
information.
What type of information must be provided concerning recognition of the medical

signs and symptoms that may limit or prevent the effective use of respirators?
An employer need only give employees medical information sufficient for them to
recognize the symptoms of medical conditions that may affect their use of respirators
as provided in Appendix C of the standard.
How extensive must the employer train employees on the general requirements of
the standard?
The discussion does not need to focus on all the details of the standard but could, for
example, simply inform employees that employers are obligated to develop a written
program, properly select respirators; evaluate respirator use; correct deficiencies in
respirator use; conduct medical evaluations; provide for the maintenance, storage, and
cleaning of respirators; and retain and provide access to specific records.
How does an employer ensure that training is conducted in a manner that is under-
standable to employees?
Employers are to develop training programs suitable to the employee’s educational
level and language background.

Under what circumstances is an employer allowed to wait before repeating training

for a new employee?
The standard provides for limited “portability” of training. An employer may wait up to 12
months from an employee’s previous training, if the employee demonstrates sufficient
knowledge concerning the training elements in section (k)(1) of the standard. This may
be accomplished through a discussion with the employee and the previous employer.
Do employees who are emergency responders need training more than once a year?
An employer must assure that an employee can demonstrate knowledge of the ele-
ments specified in (k)(1)(i) through (vii) of the standard. Employees who can not
demonstrate such knowledge must receive additional training even if they have
received training within the last 12 months.
What situations require retraining?

Retraining is needed only on those elements for which there exists a need to provide
the retraining. For example, retraining with respect to the nature of the hazard may be
necessary because of an increase in the workplace level of a hazardous substance.
Retraining under section (k)(5) is required if a change in the written respirator program
renders one or more of the elements listed in paragraph (k)(1) obsolete, thus requiring
retraining in the elements affected. Retraining is also required on any program element
of the section that is not sufficiently understood by the employee.
How often is the employer required to provide information to employees who volun-
tarily use respirators?
The standard requires that an employer initially provide the basic advisory information
in Appendix D to employees who voluntarily use respirators that are not required by
OSHA standards or the employer. Appendix D may be used, or alternatively, the
employer may develop material that is equivalent in content to this appendix. This
information may be transmitted either in written form or verbally. This information is not
required to be provided other than initially.

Use
When must respirators be worn?

Respirators must be worn whenever it is necessary to protect the health of the
employee from contaminated or oxygen deficient air, including situations where respi-
rators are necessary to protect employees in an emergency.
However, employers must first use engineering and work practice controls, where
feasible, to abate respiratory hazards. Only if such controls are not feasible, or while
they are being implemented, may an employer rely on a respirator to protect employ-
ees.
A combination of administrative controls and respirators may be used as interim con-
trols while engineering control measures are developed and implemented. However,
some of OSHA’s substance specific standards (e.g., the asbestos standard) prohibit the
use of employee rotation as an administrative control .
Must respirators be worn for chemicals that do not have PELs?

OSHA requires respirators to be worn whenever such equipment is necessary to pro-
tect the health of employees. If an exposure to an airborne contaminant, that does not
have a PEL, could result in serious illness or injury, the General Duty Clause could be
cited.
May employees who have facial hair wear respirators?

The standard requires employers to take the presence or absence of facial hair into
consideration in selecting respirators as different company policies may affect the
range of choices available. Several types of respirators such as loose-fitting hoods or
helmets accommodate facial hair. However, respirators with tight-fitting facepieces may
not to be worn by employees who have “facial hair that comes between the sealing
surface of the facepiece and the face or that interferes with valve function.”
If an employer has determined that there is no hazard, voluntary users are not prohib-
ited by the standard from wearing a beard.
What employee conditions prohibit the use of tight-fitting respirators?

An employer cannot allow employees who have any condition that interferes with the
face-to-facepiece seal or valve function to wear respirators with tight-fitting facepieces.
Examples of these conditions include, but are not limited to, missing dentures, the
presence of facial scars, the wearing of jewelry, or the use of headgear that projects
under the facepiece seal. This provision prohibits employers from placing an employee
in a tight-fitting respirator if there is any factor that could prevent an adequate

facepiece-toface seal. Respirator use is permitted where conditions such as missing

dentures or facial scars do not prevent an adequate seal.
Can corrective glasses, goggles, or other personal protective equipment be used

with tight-fitting respirators?
Corrective glasses, goggles, or other personal protective equipment can be used with
tight-fitting respirators, but employers must ensure that they are worn in a manner that
does not interfere with the seal of the facepiece to the face of the user. Eyeglass inserts
or spectacle kits are acceptable if the devices:
1. Do not interfere with the facepiece seal;
2. Do not cause any distortion of vision; and
3. Do not cause any physical harm to the wearer during use.
What is considered “other personal protective equipment?”

“Other personal protective equipment” includes faceshields, protective clothing, and
helmets, as well as to any other form of personal protective equipment that an
employee may wear that could interfere with safe respirator use.
May employees wear contact lenses with respirators?

Contact lenses may be used with respirators. Employers who have employees who
wear corrective eyewear must be sure that the respirator does not interfere with the
eyewear, make it uncomfortable, or force the employee to remove the eyewear.
Employers should use the respirator selection process to make accommodations to
ensure that their respirator-wearing employees can see properly when wearing these
devices.
What can be done if employees find it difficult to talk with coworkers when wearing
a respirator?
Some respirators may interfere with speech more than others. In these instances,
devices that enhance speech communication are available.
What procedures must be followed to perform a “user seal check?”

The “user seal check” procedures in Appendix B-1, or equally effective procedures
recommended by the respirator manufacturer, must be used. This means that respi-
rator manufacturers’ recommended procedures may be used for user seal checking if
the employer demonstrates that the manufacturer’s procedures are as effective as
those in Appendix B-1 of the standard. The “equally effective” phrase ensures that the
procedures used have been demonstrated to be effective in identifying respirators that
do not seal properly when donned or adjusted.

The user seal check cannot be performed on some tight-fitting respirators by employ-
ees with small hands who cannot block off the valves. Some manufacturers make a fit
check cup that can be used to perform a user seal check with filtering facepiece
respirators.
OSHA does not permit the use of respirators that cannot be seal checked. If no method
exists to check whether a respirator re-seals during multiple re-donnings under actual
workplace conditions, OSHA does not consider the respirator acceptable for use.
When employees must leave the respirator use area where are they supposed to go?
Employers must ensure that employees are allowed to leave the respirator use area in
several circumstances. The intent of this requirement is to ensure that employees leave
the area where respiratory protection is necessary when they need to remove the
respirator or where it appears that the respirator is not functioning properly. In these
circumstances, the standard requires employees to leave the “respirator use” area.
This does not, however, always equate with the work area or workplace. This is
intended to give employers the flexibility to establish safe areas in their workplaces that
will minimize interruptions in work flow and production while ensuring that the area
where respirators are removed is free of respiratory hazards or contamination.
When can air purifying respirators be used?

With some exceptions, air purifying respirators can be used for most air contaminants.
Respirators for gases and vapors must either be equipped with an ESLI or the
employer must implement a canister or cartridge change schedule.
Air purifying respirators must not be worn in atmospheres unknown and/or IDLH, atmo-
spheres in oxygen deficient atmospheres, or in situations where the employer cannot
prevent the canister or cartridge from becoming saturated. They also cannot be worn
if prohibited by the respirator requirements for substance specific standards (e.g.,
methylene chloride) or other OSHA standards (e.g., abrasive blasting per 29 CFR
1910.94, Ventilation). Also, respirator manufacturers have lists of contaminants for
which air purifying respirators are not recommended.
Can mouthpiece respirators be used for escape?

Yes, if the mouthpiece respirator is properly selected for the potential hazard. It is
important that escape-only respirators be NIOSH approved and appropriate for the
potential airborne concentration and class of substances involved. However, a mouth-
piece type respirator alone would not be appropriate for escape from a chlorine spill
because irritation to the eyes could impede the ability of the worker to escape. How-
ever, if chemical goggles are also provided, the use of a mouthbit respirator in
conjunction with chemical goggles might be acceptable in cases where employees can
make an immediate and unobstructed exit from an outdoor, relatively level area
involved in an emergency.

Voluntary Use
Is a written respiratory protection program required for voluntary use of filtering

facepieces?
No. An employer is obligated to determine that such respirator use will not itself create
a hazard, and to provide the respirator users with the information contained in Appendix
D of the standard.
If an employer has determined that no hazard exists, but an employee asks the
employer for a respirator because a “smell” is bothersome, would this be considered
“voluntary use?”
Yes, this is voluntary use.
Does an employer have to pay for any of the expenses associated with the voluntary
use of respirators?
The voluntary use of an elastomeric mask requires that the employer have a written 10
program, ensure the employee is medically able to use the respirator and that the
respirator does not present a health hazard, and provide a copy of Appendix D to the
employee. To the extent that the above items may create an expense, these costs
would be covered by the employer. The employer can choose to supply the respirator
and cartridges at no cost to the employee. If the employee supplies their own respirator,
the cost of the respirator and cartridges would be the responsibility of the employee.
For voluntary users wearing dust masks, the employer must provide at no cost to the
employee, a copy of Appendix D. Where respiratory protection is required either by the
employer or by the OSHA, the employer must pay all costs associated with the require-
ments set forth in the standard.

S
Table of Contents
Scissor Lifts ......................................................................................... 1

Definitions ....................................................................................... 1
Fall Protection .................................................................................. 1
Training........................................................................................... 2
Spray Booths........................................................................................ 1
Clearance........................................................................................ 1
Lighting ........................................................................................... 1
Maintenance .................................................................................... 2
Storage ........................................................................................... 2
Use ................................................................................................ 3
Stairs ................................................................................................... 1
Handrails......................................................................................... 1
Platforms......................................................................................... 1
Tread.............................................................................................. 2
Storage Racks ...................................................................................... 1
Anchoring ........................................................................................ 1
Condition......................................................................................... 1
Inspections ...................................................................................... 2
Installation ....................................................................................... 3
3/13 S–1
Reserved
2–S 3/13
Scissor Lifts
Definitions
What is a scissor lift?

A scissor lift is a mobile scaffold for which the platform only moves vertically.
Scissor lifts do not include any of the following:
• Aerial lifts,
• Manlifts,
• Mobile ladder stands, or
• Scaffolding (towers).
Fall Protection
Do employees need to be tied-off when working from a scissor lift?

While OSHA does not have a general industry standard that specifically addresses
scissor lifts, the agency regards a scissor lift as a scaffold. This is specified in an
August, 01, 2000 Letter of Interpretation (LOI). In that letter, the agency says that if the
scissor lift has guardrails that meet OSHA requirements that is all that is required for fall
protection. In other words, employees do not have to tie-off in a scissor lift if it has
guardrails.
However, OSHA further addresses this issue in a LOI dated July 21, 1998 which says:
“In regards to your specific question, when working from an elevated scissors lift (ANSI
A92.6 series), a worker need only be protected from falling by a properly designed and
maintained guardrail system. 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. The general scaffolding fall protection provision
found in 1926.451(g)(1)(vii) reads in part, “for all scaffolds not otherwise specified in this
section, each employee shall be protected by the use of personal fall arrest systems or
guardrails systems.”” [bold emphasis added]
3/13 Scissor Lifts–1

Training
What training is required for scissor lifts?

OSHA does not prescribe training requirements for scissor lifts used in general indus-
try; however, the agency says in a July 2011 Hazard Alert that operators need to be
trained. Specifically, OSHA says training must be based on the manufacturer’s instruc-
tions and recommendations outlined in the operator’s manual for each lift, as well as
safe work practices established by the employer. The American National Standards
Institute (ANSI) also says employers must train both operators and maintenance per-
sonnel in accordance with the equipment manufacturer’s recommendations, as well as
those outlined in applicable ANSI standards. The ANSI standards covering scissor lifts
are:
• A92.3 – Manually Propelled Elevating Aerial Platforms
• A92.6 – Self-Propelled Elevating Work Platforms
Following the recommendations of the manufacturer, as well as those outlined in the
applicable ANSI standard, will help ensure that operation, maintenance, and safety
features specific to each scissor lift are clearly understood.
Specifically, ANSI says that prior to operating a scissor lift, operators must be both
trained and evaluated. That training must be equipment specific and include informa-
tion on:
• Location, purpose, and use of manuals;
• Pre-start inspections;
• Operating instructions;
• Purpose and use of controls;
• Safety features;
• Placards and decals;
• Warnings; and
• Safety rules and regulations.
ANSI says that training regarding proper and safe operation of the lift must include (but
is not limited to) information on the following:
• Fall protection,
• Slope and grade,
• Stabilization,
• Securement,
• Capacity and ratings,
2–Scissor Lifts 3/13

• Loading,
• Clearances and other precautions,
• Entanglement,
• Electrical hazards
• Driving,
• Travel speeds,
• Personal protective equipment,
• Safety measures while working on the platform,
• Fueling,
• Battery charging,
• Modifications,
• Worksite and work area hazards, and
• Reporting malfunctions, and hazards
If used for construction work, employers must comply with 1926.454, “Training require-
ments” as OSHA considers a scissor lift as scaffold as referenced in a February 23,
2000 and August 1, 2000 LOIs.
3/13 Scissor Lifts–3

Reserved
4–Scissor Lifts 3/13

Spray Booths
Clearance
What is the required clearance around a spray booth?

At 1910.107(b)(8) OSHA requires that the outside of each spray booth be separated
from other operations by at least 3 feet or greater, or by a partition or wall to reduce the
danger from juxtaposition of hazardous operations.
Is there a minimum or maximum door size for spray booths?

OSHA does not have a minimum or a maximum door size for spray booths. OSHA
spray booth construction requirements are at 1910.107. As long as the booth meets
these requirements, the door size is irrelevant.
In an archived OSHA Technical Support Document dated November 04, 1976, the
agency states “In any discussion of spray booths the physical size of the booth
becomes of prime importance since the size of the booth may range from something
which will accommodate a product 1 inch in length by 1 inch in width by 1 inch in height
to a booth which will accommodate an object 20 feet in width by 25 feet in height and
100 feet in length. Obviously, the requirements of each of these booths would be
radically different in relation to personal protective equipment and ventilation.” The
focus is on what the function of the booth is, rather than door size.
Also, clearances may be addressed in a local building and fire code.
Lighting
What is the requirement for explosion proof lighting in a spray booth?

OSHA says that an employer must determine if the booth is a hazardous location per
1910.307. The definitions for the hazardous locations are found at 1910.399. If it is
determined that the booth is a hazardous location, all lighting and other electrical
devices must be “intrinsically safe” for that location, and be so marked. According the
NFPA 33, “Standard for Spray Application Using Flammable or Combustible Materials,”
non-intrinsically safe fixtures must be ate least 10 feet vertically and 20 feet horizontally
from a Category I or II hazard.
3/13 Spray Booths–1

Maintenance
How often must spray booths be cleaned?

OSHA says at 1910.107(g)(2) that all spraying areas (including sprinkler heads) must
be kept as free from the accumulation of deposits of combustible residues as practical,
with cleaning conducted daily if necessary. Scrapers, spuds, and other tools used for
cleaning purposes must be of nonsparking material.
How must spray booths be cleaned?

Solvents used for cleaning spray booth must have a flashpoint of more than 100°F;
however, for cleaning spray nozzles and auxiliary equipment, then solvents having
flash points not less than those normally used in spray operations may be used. All
cleaning must be conducted inside spray booths and the ventilating equipment must be
operated during cleaning.
Are any type of signs required in spray booths?

“No smoking” signs in large letters on contrasting color background must be conspicu-
ously posted at all spraying areas and paint storage rooms.
Storage
How much paint or solvent may be kept inside a spray booth?

Flammable liquids may not be stored in a spray booth. At 1910.107(e)(2) OSHA states
“The quantity of flammable liquids or liquids with a flashpoint greater than 199.4°F
(93°C) kept in the vicinity of spraying operations shall be the minimum required for
operations and should ordinarily not exceed a supply for 1 day or one shift.” Mixing
paints or filling paint guns in the booth is also prohibited. And hazardous waste may
also not be stored in the paint booth per 1910.106(e)(9)(iii).
2–Spray Booths 3/13

Use
Can different types of sprays be used in the same booth?

Spray booths can not be alternately used for different types of coating materials if the
combination of the materials may be conducive to spontaneous ignition, unless all
deposits of the first used material are removed from the booth and exhaust ducts prior
to spraying with the second used material.
Do spray booths need to be grounded?

If using flammable liquids or liquids with a flashpoint greater than 199.4°F (93°C) or
aerated solids, all metal parts of the spray booth, exhaust ducts, and piping systems
must be properly electrically grounded in an effective and permanent manner.
3/13 Spray Booths–3

Reserved
4–Spray Booths 3/13

Stairs
Handrails
How many handrails must a fixed stairs have?

The number of handrails required depends on the width of the stairway as prescribed
under 1910.23(d). Specifically, if the stairway is less than 44 inches wide and only one
side is enclosed, a handrail is needed only on the open side. However, if the stairway
is more than 44 inches wide, but less than 88 inches, a handrail is needed on both
sides. If the stairway is more than 88 inches, a handrail is also needed on the enclosed
side and a stair railing must be located in the middle of the stairs.
Platforms
How long can a flight of fixed stairs be without a platform or landing?

OSHA provides no requirements regarding the exact number or placement of stairway
platforms. However, the National Safety Council recommends landings at every tenth
or twelfth tread. Also, state or local building code may dictate platform requirements.
What are the required dimensions for a stairway platform?

OSHA’s requirements for stairway platforms at 1910.24(g) states that they must be “no
less than the width of a stairway and a minimum of 30 inches in length measures in the
direction of travel.”
If you have a set of stairs that consists of three actual steps and then a platform, are
handrails and midrails required?
OSHA defines a platform as “an extended step...” In addition, the definition of a stairs/
stairway is “a series of steps and landings having three or more risers.” In this case, the
number of steps plus the platform would require a handrail and possibly a midrail (that
depends on the width of the stairway) under 1910.23(d).
Stairs–1
Tread
Must the leading edge or nose of stairway steps be marked or painted?

OSHA does not require that steps be marked or painted. However, in certain cases a
hazard may be presented (e.g., if lighting is such that employees are unable to
adequately see the steps to use them safely). In these situations, it would be the
employer’s responsibility under The General Duty Clause to abate that hazard. This
may be accomplished by various means, including painting the leading edge or nose
of each step, providing additional lighting, posting warning signs, etc.
2–Stairs
Storage Racks
Anchoring
Do storage racks need to be anchored or bolted to the floor or wall?

There is not a specific requirement from OSHA regarding anchoring storage racks.
However, OSHA has used the General Duty Clause to hold employers responsible for
storage rack safety. In fact, the following is an excerpt from a November 13, 2006
General Duty Clause citation:
“...employer did not furnish employment and a place of employment which were free
from recognized hazards that were causing or likely to cause death or serious physical
harm to employees in that employees were exposed to...crushing hazards from not
anchoring the storage rack systems. The storage racks are used to store various
gauge metal sheets, parts and products. The storage racks systems range in height
from 4 to 6 tiers. In addition, load capacity rating plaques were not in place to state the
storage capacity of the systems. Among other methods, one feasible and acceptable
abatement method to correct this hazard is to anchor the storage racks systems and
install load capacity plaques in accordance with ANSI MH 16.1, “Specification for the
Design, Testing, and Utilization of Industrial Steel Storage Racks.”” [bold emphasis
added]
Employers should also consult the anchoring recommendations provided by the stor-
age rack manufacturer.
Condition
Do damaged storage racks need to be replaced?

While OSHA does not have a specific standard regarding storage racks, the agency
does use the General Duty Clause to cite employers for hazards in the absence of clear
regulations. The following an excerpt from an August, 5, 2010 General Duty Clause
citation regarding damaged racking:
“...Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did
ees in that employees were exposed to the hazard of crushing or being struck by
stored materials on damaged shelving: a) Location - Warehouse area, metal storage
racking system: On or about May 4, 2010, the metal storage racking system was
Storage Racks–1
damaged from forklift traffic, significantly compromising the structural integrity of the
system. Among other methods, feasible and acceptable means to correct these haz-
ards include:
1. Complying with the requirements outlined in the American National Standards
Institute, ANSI MH16.1, “Specification for the Design, Testing, and Utilization
of Industrial Steel Storage Racks.”
2. To repair or replace all damaged metal storage racks as per manufacturer’’s
specifications.
3. To develop a maintenance program designed to recognize weakness in the
rack system in order to prevent a structural collapse.” [bold emphasis added]
Do storage racks need corner guards?

Even though there is not a specific requirement from OSHA regarding storage racks,
the agency does expect racking to be inspected, used, and maintained safely (usually
per the manufacturer’s instructions). Therefore, employers should consult the rack
supplier for available damage-prevention solutions based on their use and operations.
Inspections
How often do storage racks need to be inspected?

The maintenance of storage racks can be cited under the General Duty Clause. In fact,
the following is taken from an October 03, 2006 General Duty Clause citation:
“...Section 5(a)1 of the Occupational Safety and Health Act of 1970: The employer did
ees in that employees were exposed to crushing hazards from steel rack units and/or
its contents: Warehouse - the racking/shelving which support motors and other parts
averaging 500 pounds and less were placed on damaged racks/shelving, the
employer did not ensure that steel storage racks in use at the facility were
inspected and maintained in accordance with the manufacturer’s requirements and
with the American National Standards Institute guideline for use of industrial and com-
mercial steel storage racks. Among other methods, one feasible and acceptable
method to correct this hazard is to follow the recommendations of the Rack Manufac-
turers Institute guidelines for the use of industrial and commercial steel storage
racks…” [bold emphasis added]
Similarly, in a December 14, 2006 General Duty Clause citation, OSHA said:
“...Section 5(a)1 of the Occupational Safety and Health Act of 1970: The employer did
ees in that employees were exposed to crushing hazards from steel rack units:
2–Storage Racks
Warehouse - the racking/shelving which support food products approximately 2400

pounds were placed on damaged racks/shelving, the employer did not ensure that
steel storage racks in use at the facility were inspected and maintained in accor-
dance with the manufacturer’s requirements and with the American National Standards
Institute guideline for use of industrial and commercial steel storage racks. Among
other methods, one feasible and acceptable method to correct this hazard is to follow
the recommendations of the Rack Manufacturers Institute guidelines for the use of
industrial and commercial steel storage racks…” [bold emphasis added]
As noted above, in using the General Duty Clause, OSHA references the manufactur-
er’s guidelines as well as industry/ANSI standards.
Note: Another potentially applicable OSHA standard would be 1910.176(b), which
states, “Storage of material shall not create a hazard. Bags, containers, bundles, etc.,
stored in tiers shall be stacked, blocked, interlocked and limited in height so that they
are stable and secure against sliding or collapse.”
Installation
What is the maximum or recommended height of storage racks?

There is not a specific requirement from OSHA regarding storage racks. However, in
terms of general storage safety, OSHA requires under 1910.176(b) that, “Storage of
material shall not create a hazard. Bags, containers, bundles, etc., stored in tiers shall
be stacked, blocked, interlocked and limited in height so that they are stable and secure
against sliding or collapse.”
OSHA also requires at 1910.159(c)(10) regarding sprinkler clearance that when stack-
ing items, “The minimum vertical clearance between sprinklers and material below shall
be 18 inches (45.7 cm).”
Do storage racks need to be marked with load ratings?

OSHA does not have a specific regulation regarding load ratings of storage racks.
However, OSHA has used the General Duty Clause to hold employers responsible for
storage rack safety, often referencing the manufacturer’s recommendations, or an
ANSI/industry standard. In fact, the following is an excerpt from an November 13, 2006
General Duty Clause citation:
“...employer did not furnish employment and a place of employment which were free
from recognized hazards that were causing or likely to cause death or serious physical
Storage Racks–3
harm to employees in that employees were exposed to...crushing hazards from not
anchoring the storage rack systems. The storage racks are used to store various gauge
metal sheets, parts and products. The storage racks systems range in height from 4 to
6 tiers. In addition, load capacity rating plaques were not in place to state the storage
capacity of the systems. Among other methods, one feasible and acceptable abate-
ment method to correct this hazard is to anchor the storage racks systems and install
load capacity plaques in accordance with ANSI MH 16.1, “Specification for the
Design, Testing, and Utilization of Industrial Steel Storage Racks.”” [bold emphasis
added]
And, in a 12/23/2005 General Duty Clause citation, OSHA said:
“…employees were exposed to crushing injuries from the failure of steel racks ... the
employer did not have the home-made racking systems conform with the requirements
of ANSI MH 16.1-1974. The rated load capacities of the storage racks were
unknown and the load capacities were not marked on the storage racks. Among
other methods, one feasible and acceptable means of abatement, is to determine the
capacity of the storage racks and have the design of the racks certified by a profes-
sional engineer…” [bold emphasis added]
Also note that local building/safety codes may have specific requirements for load
rating postings.
4–Storage Racks
T/U/V
Table of Contents
Training................................................................................................ 1
Recordkeeping ................................................................................. 1
Refresher Training ............................................................................ 1
Required Training ............................................................................. 2
Trainer Qualifications ....................................................................... 25
9/12 T/U/V–1
Reserved
2–T/U/V 9/12
Training
Recordkeeping
Does training need to be documented?

Training must be documented as required by the applicable OSHA standard. Generally,
training documentation requires the employer and trainers to sign a certification record
which includes the identity of the person(s) trained. If a standard does not specify
documentation requirements, common industry practice is to take attence of all
employees who attended the training session; however, OSHA does not require sig-
natures from employees who have attended training sessions.
How long must training records be kept?

Training records must be retained as required by the applicable OSHA standard. This
varies from standard to standard. Even if a rule does not specifically require a record
retention time, employers should establish a policy for doing so as a best practice.
Refresher Training
When is retraining necessary?

Retraining must be conducted as required by the applicable OSHA standard. Other
standards require retraining “as needed,” when there are changes in the workplace that
would affect previous training, or when certain other circumstances indicate that
retraining is needed. For example, the Powered Industrial Trucks standard requires
forklift drivers to be evaluated at least every three years — the standard outlines
conditions that require refresher forklift operator training at 1910.178(l)(4).
Also, an employer should periodically review their safety program to identify areas that
need improvement. Employee refresher training can help address problems involving
a lack of knowledge regarding hazards, procedures, or equipment.
9/12 Training–1
Required Training
What training is required by OSHA?

Providing workers with complete information regarding processes they are involved in,
equipment they might need to use, the necessary protection required to do the task
safety, and potential effects from chemical exposure are just a few of the important
elements of OSHA compliance. More than 100 of OSHA’s current standards contain
specific training requirements.
The following table is a summary of required OSHA training for general industry. Each
entry describes who must be trained, when they must be trained, and any associated
recordkeeping requirements. Employers should refer to the actual regulation for clari-
fication and further guidance.
Required General Industry OSHA Training At-A-Glance

* Indicates annual training is required.
Injury and Illness Recordkeeping — Employee Involvement (1904.35)
Who: Train employees on how to report a work-related injury or illness
When: Initially
What records: Specific training documentation is not required
Emergency Action Plans (1910.38)

Who: Train employees who need to evacuate the facility in an emergency
When: • Initially
• When the employee’s responsibilities change
• When the plan is changed
What records: Keep written plan in the workplace
Fire Prevention Plans (1910.39)

Who: Train employees who are exposed to fire hazards
When: Initially
What records: Keep written plan in the workplace
2–Training 9/12
Powered Platforms (1910.66)

Who: Train employees who operate powered platforms
When: Initially
What records: • Keep a training certificate that includes:
❍ employee’s name
❍ signature of the employer or trainer
❍ date of the training
• Keep training records for the duration of employment
Occupational Noise Exposure (1910.95)*

Who: Train employees who are exposed to noise at or above an 8-hour
time-weighted average of 85 decibels
When: • Initially, preceding exposure to noise level
• Repeat annually
Flammable Liquids (1910.106)

Who: • Train storage tank station operators
• Train emergency responders for storage tanks in flood-prone
areas
When: Initially, or prior to taking part in emergency operations
Explosives and Blasting Agents (1910.109)

Who: Train motor vehicle operators who transport explosives
When: Initially, or prior to transporting any quantity of explosives
What records: Drivers must have a valid motor vehicle operator’s license.
Specific training documentation is not required
Storage and Handling of Liquefied Petroleum Gases (1910.110)

Who: • Train employees who install, remove, operate, and maintain LP
gas systems
• Train employees who perform a standard watch service for an
area that includes an LP gas installation
When: Initially, or prior to assignment
Storage and Handling of Anhydrous Ammonia (1910.111)

Who: Train employees responsible for tank car unloading operations
9/12 Training–3
Process Safety Management of Highly Hazardous Chemicals (1910.119)

Who: • Train employees who operate a process
• Inform contract employees of known potential fire, explosion, or
toxic release hazards related to the contractor’s work and process
When: • Initially
• Repeat at least every three years
What records: • Keep a training certificate that includes:
❍ method used to verify that training was understood
• Written operating procedures are required
Hazardous Waste Operations and Emergency Response — HAZWOPER

(1910.120)*
Who: • Train employees who work at a hazardous waste site under
1910.120(e)
• Train managers or supervisors at a hazardous waste site under
1910.120(e)
• Train employees who work at Treatment, Storage, and Disposal
(TSD) facilities under 1910.120(p)
• Train employees who will participate in emergency response to
hazardous substance releases under 1910.120(q)
When: • Hazardous waste site employees:
❍ initially before they participate in field activities
❍ repeat annually
• TSD facility employees:

❍ initially
❍ repeat annually
• Emergency responders to hazardous substance releases:

❍ initially, or prior to taking part in actual emergency operations
❍ repeat annually
What records: Training certification is required under:

• General training 1910.120(e)
• Operations conducted under RCRA 1910.120(p)
• Emergency response to hazardous substance releases
1910.120(q)
4–Training 9/12
Dipping and Coating Operations (1910.122-.126)

Who: Train employees who work in and around open-surface tank opera-
tions in appropriate first aid procedures
When: Initially
Personal Protective Equipment (1910.132)

Who: Train employees who will use personal protective equipment
When: • Initially
• Retrain as necessary
Respiratory Protection (1910.134)*

Who: Train employees who will use a respirator
When: • Initially, or before using a respirator
• Repeat annually
• Repeat whenever necessary to ensure safe use
What records: • Specific training documentation is not required
• Documentation is required for medical evaluations and fit testing
Temporary Labor Camps (1910.142)

Who: Train emergency first aid providers
When: Initially, or prior to responding to any emergency situation
What records: • Specific training documentation is not required
• First aid facilities must be approved by a health authority
Specifications for Accident Prevention Signs and Tags (1910.145)

Who: Train employees who work in areas where warnings are used to
communicate hazards
When: Initially, or prior to working in areas where signage is used
9/12 Training–5
Permit-Required Confined Spaces (1910.146)*

Who: Train employees who have roles in permit space entries
When: • Employee rescue service personnel have to perform practice res-
cues at least annually
• All employees who have permit-required confined space duties
have to be trained:
❍ initially
❍ when an employee’s duties change
❍ when hazards in the space change
❍ when there are deviations from the permit space entry proce-
dures
❍ when the employee’s knowledge of entry procedures are inad-
equate
What records: • Entry supervisors must fill out and sign an entry permit
• Keep canceled entry permits at least one year
• Keep training certificates that include:
❍ signature or initials of the trainer
❍ date of training
Lockout/Tagout (1910.147)
Who: Train employees:
• Who perform service or maintenance on equipment that must be
locked out or tagged
• Who operate equipment that is locked out (affected employees)
When: • Initially, or prior to performing service or maintenance on equip-
ment or a system
• As needed for employee proficiency
• When there are new or revised procedures
What records: Keep a training certificate that includes:
• Employee’s name
• Date of training
Medical Services and First Aid (1910.151)

Who: Train employees designated as first aid providers
When: Initially, or prior to responding to first aid emergencies
6–Training 9/12
Fire Brigades (1910.156)*

Who: Train fire brigade members
When: • Initially, or prior to performing emergency activities
• Repeat at least annually
• Quarterly educational session for brigade members expected to
fight interior structural fires
What records: • Keep written procedures, including training and education pro-
gram information
• Keep a copy of the workplace emergency action plan
• Document previous training received as part of the community
Portable Fire Extinguishers (1910.157)*

Who: • Train employees when there are portable fire extinguishers for
employee use
• Train employees who are designated to use fire fighting equip-
ment as part of an emergency action plan
When: • Initially
• Repeat at least annually
Standpipe and Hose Systems (1910.158)

Who: Train employees who will conduct inspections on standpipe and
hose systems
Fixed Extinguishing Systems, General (1910.160)*

Who: Train employees who will inspect, maintain, operate, or repair fixed
extinguishing systems
When: • Initially, or prior to assignment
• Review annually to keep employees’ performance up-to-date
Fire Detection Systems (1910.164)

Who: Train employees who will service, maintain, test, clean, and make
sensitivity adjustments to automatic fire detection systems.
9/12 Training–7
Employee Alarm Systems (1910.165)

Who: • Train employees who service, maintain, and test alarm systems
• Train employees on how to report emergencies
Servicing Single Piece and Multi-Piece Rim Wheels (1910.177)

Who: Train employees who service multi-piece rim wheels on the hazards
involved and safe practice to follow
• Repeat whenever necessary to ensure employee proficiency
Powered Industrial Trucks (1910.178)

Who: Train and evaluate employees who operate powered industrial
trucks
When: • Initially, or prior to operating a vehicle without direct supervision
• Refresher training is required when:
❍ the vehicle is operated unsafely
❍ after an accident or near-miss
❍ when an evaluation shows retraining is needed
❍ when assigned to a different type of vehicle
❍ when changes in the workplace affect safe truck operation
• Evaluate at least every three years

What records: • Certify that the operator has been trained and evaluated
• Training documentation must include:
❍ operator’s name
❍ dates of the training and evaluation
❍ name of the trainer/evaluator
Overhead and Gantry Cranes (1910.179)

Who: • Train crane operators to use portable fire extinguishers
• A qualified person must be responsible for operations when two or
more cranes are used to lift a load
8–Training 9/12
Crawler Locomotive and Truck Cranes (1910.180)

Who: Train operating and maintenance employees to use portable fire
extinguishers
Mechanical Power Presses (1910.217)*

• Who operate power presses
• Who are assigned to care for, inspect, and maintain power
presses
When: • Operators of part revolution power presses used in the PSDI
mode:
❍ initially, or prior to operating the equipment
❍ at least annually thereafter
• Power press operators prior to initial assignment

• Maintenance employees:
❍ initially or prior to assignment
❍ periodically thereafter
What records: • Training certificate required for operators of part revolution power
presses used in the PSDI mode that includes:
❍ name of the employee
❍ signature of the employer or the person conducting the training
❍ keep certification record for the duration of employment
• Specific training documentation is not required for:

operators of other types of power presses
power press maintenance personnel
Forging Machines (1910.218)

Who: Train employees assigned to inspection and maintenance activities
What records: • No specific training documentation is required
• Certification is required for inspections
Welding, Cutting, and Brazing (1910.252)

Who: • Train cutters, welders, and their supervisors in safe equipment
operation
• Train fire watchers to use fire extinguishing equipment
What records: No specific training documentation is required
9/12 Training–9
Oxygen-Fuel Gas Welding and Cutting (1910.253)

Who: Train employees in charge of the oxygen or fuel-gas supply equip-
ment
When: Initially, and judged competent prior to assignment
Arc Welding and Cutting (1910.254)

Who: Train employees who will operate arc welding equipment
Resistance Welding (1910.255)

Who: Train employees who will operate resistance welding equipment
Pulp, Paper, and Paperboard Mills (1910.261)

Who: Train employees exposed to chlorine gas during bleaching opera-
tions
• Industry consensus standards have additional training require-
ments
• Industry consensus standards have refresher training require-
ments
• Industry consensus standards may have documentation require-
ments
Laundry Machinery and Operations (1910.264)

Who: Train employees exposed to laundry operations and machinery haz-
ards
10–Training 9/12
Sawmills (1910.265)
Who: Train employees exposed to sawmill operations, excluding those
involving the manufacture of plywood, cooperage, and veneer
• Industry consensus standards and applicable OSHA regulations
may have additional training requirements
may require refresher training
may require documentation
Logging Operations (1910.266)

Who: Train employees and supervisors exposed to logging operations
• When assigned new tasks, tools, equipment, machines, or
vehicles
• When demonstrating unsafe job performance
• Current certification in first aid and CPR is required
• New employees who have been previously trained do not need
to be retrained in those elements prior to initial assignment
What records: • Training certification record must include:
❍ name of employee
❍ date of training
❍ signature of trainer
❍ signature of employer
❍ date of acceptance of applicable prior training
• Retain the most recent certification record
Telecommunications (1910.268)
Who: Train employees exposed to hazards involving telecommunication
work
When: Prior to participating in telecommunications activities
What records: • A written description of the training program
• Document employee training
• Retain training certification record for each employee during the
period of employment
9/14 Training–11
Electric Power Generation, Transmission, and Distribution (1910.269)

Who: • Train all employees performing electric power generation,
transmission, and distribution work, to include safety practices
and procedures for their assignments and applicable emergency
procedures.
• Training can be either classroom or on-the-job.
• Train each employee in other safety practices, including
emergency procedures (such as pole-top and manhole rescue),
not specifically addressed but are necessary for his or her
safety.
• The degree of training is determined by the risk to the
employee.
• Qualified employees must be trained and competent in
distinguishing exposed live parts, determining nominal voltage,
minimum approach distances, use of precautionary techniques,
PPE, insulating and shielding materials, insulated tools, and
recognition of electrical hazards.
• The training must address selection of a proper working
position.
• Non-qualified line-clearance tree trimmers must also be trained
in distinguishing exposed live parts, determining nominal
voltage, and minimum approach distances.
• Employer must determine through supervision and inspection
conducted annually that each employee is complying with the
safety-related work practices required.
• Host/contractor information transfer.
• First-aid training in some circumstances.
• Daily job briefings by the employee in charge of the job.
• Lockout/tagout, enclosed space, and confined-space training, as
applicable.
• Test area employees must be trained upon initial assignment to
the test area.
• Training for employees performing live-line barehand work on
energized circuits.
• Training for coal- or ash-handling conveyor operation, as
applicable.
• Training for line-clearance tree trimmers must include the
special techniques and hazards involved.
• Qualified persons must be knowledgeable in the construction
and operation of the electric power generation, transmission,
and distribution equipment involved, along with the associated
hazards.
12–Training 9/14
When: • Before exposure.

• Train or retrain if the supervision determines a deficiency or if
new technology, new equipment, or changes in procedures
require the use of safety-related work practices that are different
from those normally used.
• Require each employee to demonstrate proficiency in the work
practices required.
• Retrain when tasks are performed less than once per year.
What records: Though they are not required, employment records that indicate
that an employee has successfully completed the required
electrical training are one way of keeping track of when an
employee has demonstrated proficiency.
Certification of lockout/tagout training is required to include name
and dates of training, confined space training certification must
also include trainer’s signature or initials.
For an employee with previous training, an employer may
determine that the employee has demonstrated the proficiency
required using the following process: (1) Confirm that the
employee has the training required, (2) Use an examination or
interview to make an initial determination that the employee
understands the relevant safety-related work practices before he
or she performs any work, and (3) Supervise the employee
closely until that employee has demonstrated proficiency as
required.
Grain Handling Facilities (1910.272)*

Who: Train employees involved in grain handling operations
• When new job assignments expose the employee to different
hazards
• At least annually
Electrical Training (1910.332)

Who : Train employees:
• Exposed to electric shock
• Who work on or near exposed energized parts
When: Prior to exposure (classroom or on-the-job)
9/14 Training–13
Commercial Diving (1910.410)

Who: Train employees who are commercial dive team members
When: Prior to conducting any tasks on the dive team
Asbestos (1910.1001)*
Who: Train employees who are exposed to airborne concentrations of
asbestos at or above the action level
• At least annually thereafter
What records: • Document employee training
• Keep training certification record for one year beyond the
employee’s last day of employment
13 Carcinogens (1910.1003 Through 1910.1016)*

Who: • Train authorized employees (those assigned to work where a
regulated carcinogen is manufactured, processed, used,
repackaged, released, handled, or stored)
• Train employees who wear respirators according to 1910.134
When: • Prior to being authorized to enter a regulated area
Vinyl Chloride (1910.1017)*

Who: • Train employees:
• Who work in covered vinyl chloride or polyvinyl chloride
operations
• Who wear respirators according to 1910.134
14–Training 9/14
Inorganic Arsenic (1910.1018)*

Who: • Train employees exposed to inorganic arsenic:
❍ above the action level (without regard to respirator use)
❍ when the possibility of skin or eye irritation exists in covered
operations
• Train employees who clean or launder contaminated protective
clothing
When: • Initially
• Within five working days after receiving exposure results, notify
each employee in writing of those results
What records: • Provide specific information to physicians who conduct medical
surveillance
• Provide each employee with a copy of the physician’s written
opinion
• Provide all materials relating to the employee information and
training program to OSHA and NIOSH
• Provide a copy of 1910.1018 and its appendices to covered
employees
• Retain exposure monitoring and medical surveillance records
for at least 40 years or the duration of employment plus 20
years, whichever is longer
Access to Employee Exposure and Medical Records (1910.1020)*

Who: Train all employees
When: • Initially, at the time of hire
What records: • No specific training documentation is required
• Provide copies of 1910.1020 and its appendices to all
employees
9/14 Training–15
Lead (1910.1025)*
• With potential exposure to airborne lead
• Exposed to airborne lead at or above the action level
• Who are at risk of skin or eye irritation
• Who use respirators according to 1910.134
• Who clean or launder contaminated protective clothing
each employee in writing of his or her exposure level
examinations
opinion
training program to OSHA and NIOSH upon request
• Provide a copy of §1910.1025 and its appendices to covered
employees
for at least 40 years or the duration of employment plus 20
years, whichever is longer
Chromium (VI) (1910.1026)

Who: Train employees who are exposed to chromium (VI)
When: In addition to the requirements of the Hazard Communication
standard at 1910.1200(h), the employer has to:
• Ensure that each employee can demonstrate knowledge of at
least the contents of the 1910.1026 Chromium (VI) standard,
and the purpose and a description of the medical surveillance
program.
• Provide respiratory protection when engineering and work
practice controls do not reduce chromium exposures at or
below the PEL and for emergency situations. Where respirators
are required, employees need to be trained to use the
equipment properly according to 1910.134(k).
Additionally, when employees have to wear protective clothing and
equipment to protect them from skin and eye contact with
chromium (VI), training in the proper use must be provided
according to 1910.132(f).
What records: A copy of the Chromium (VI) standard has to be made available
at no cost to all affected employees.
16–Training 9/14
Cadmium (1910.1027)*
• With potential exposure to cadmium
• With exposure to hazardous substances according to
1910.1200
• Who clean or launder contaminated protective clothing about
exposure hazards
• Within 15 working days after receiving exposure results, notify
each employee in writing of his or her exposure level and post
the results
• Within 30 days of an employee request, provide the information
that was given to the physician
• Within two weeks of receipt, provide each employee with a copy
of the physician’s written opinion
examinations
training program to OSHA upon request
• Make a copy of 1910.1027 and its appendices available to
affected employees
• Retain exposure monitoring for at least 30 years, and retain
medical surveillance records for at least the duration of
employment plus 30 years
Benzene (1910.1028)*
Who: Train employees who are exposed to airborne concentrations of
benzene at or above the action level.
9/14 Training–17
Coke Oven Emissions (1910.1029)*

• Assigned to work in a regulated area
• Who refuse to participate in the medical surveillance program of
the possible health consequences
examinations
opinion
• Obtain signed statements from employees who refuse to
participate in the medical surveillance program that they
understand the risks involved
• Maintain records of the training program content
• Post appropriate procedures and schedules in the regulated
area
covered employees
for the duration of employment plus 30 years
Bloodborne Pathogens (1910.1030)*

Who: Train employees with occupational exposure to bloodborne
pathogens
When: • Prior to initial exposure to bloodborne pathogens
What records: Maintain for three years specific training records including:
• dates
• training content
• names and qualifications of trainers
• names and job titles of those trained
18–Training 9/14
Cotton Dust (1910.1043)*

• Exposed to cotton dust in covered operations
• When job assignments or work processes change
• When performance indicates a need for retraining
• Within 20 working days after receiving exposure results, notify
examinations
opinion
• Post a copy of 1910.1043 and its appendices, and make copies
available to employees upon request
• Maintain a record of the training program contents
9/14 Training–19
1,2-Dibromo-3-Chloropropane (1910.1044)*
• Who are occupationally exposed to 1,2-dibromo-3-
chloropropane (DBCP)
exposure hazards
When: • Annually inform employees of the information in Appendix A of
1910.1044
• Within five working days after receiving monitoring results, notify
examinations
opinion
• Maintain a record of the training program contents
affected employees
20–Training 9/14
Acrylonitrile (1910.1045)*
• Who are occupationally exposed to acrylonitrile (AN)
• Who use personal protective equipment according to 1910.132
• Who clean or launder contaminated protective clothing of the
hazards of exposure
When: • At the time of initial assignment
• Within five working days after receiving monitoring results, notify
examinations
opinion
• Maintain a record of the training program contents, including a
certificate under 1910.132
affected employees
9/14 Training–21
Ethylene Oxide (1910.1047)*

• Who have potential exposure to Ethylene oxide (EtO) at or
above the action level, or above the excursion limit
• In emergency action procedures according to 1910.38
• Within 15 working days after receiving monitoring results, notify
each employee of his or her exposure level either individually in
writing or by posting the results
• Within 15 days of receipt, provide each employee with a copy of
the physician’s written opinion
examinations
employees
• Maintain a training certificate according to 1910.132
22–Training 9/14
Formaldehyde (1910.1048)*
• Assigned to workplaces with exposure to formaldehyde at or
above 0.1 ppm
exposure hazards
• At least annual thereafter
• Whenever a new exposure to formaldehyde is introduced
writing or by posting the results
examinations
• Maintain a record of the training program contents, including
records under 1910.132 and 1910.134
• Provide all materials relating to the program to employees and
to OSHA upon request
9/14 Training–23
Methylenedianiline (1910.1050)*
• Who may be exposed to airborne Methylenedianiline (MDA) at
or above its action level or where dermal exposure to MDA can
occur
• In emergency action procedures according to 1910.38
exposure hazards
writing or by posting the results.
What records: • Maintain a record of the training program contents
• Provide specific information physicians who conduct medical
surveillance
• Provide all materials relating to the program to employees and
to OSHA and NIOSH upon request
employees.
1,3-Butadiene (BD) (1910.1051)*

Who: Train employees with occupational exposure to 1,3-butadiene
When: • At or before the time of initial assignment
• At least annually thereafter when employees are exposed over
the action level or STEL
What records: • Maintain records according to 1910.1200
• Establish and maintain objective data records relevant to BD
exemption
Methylene Chloride (MC) (1910.1052)

Who: Train employees potentially exposed to methylene chloride
• Retrain on an as-needed basis
What records: No recordkeeping requirements are specified
24–Training 9/14
Ionizing Radiation (1910.1096)*

Who: Train employees working in or frequenting any portion of a
covered radiation area
When: • Annually inform employees of individual exposure monitoring
results
• Following a reportable exposure incident, provide written
notification of exposure to the exposed employee
What records: • Post a copy of the regulation along with copies of operating
procedures, or keep them available for employees upon request
Hazard Communication (1910.1200)

Who: Train employees with exposure or potential exposure to
hazardous chemicals
When: • Prior to initial exposure
• When a new chemical hazard is introduced
• Note: Employees must also be trained on the March 26, 2012,
changes to the Hazcom standard. These changes incorporate
the GHS system of classification and labeling of chemicals. In
particular, employees must be trained on the new pictograms,
labels, and safety data sheets, by Dec. 1, 2013.
Occupational Exposure to Hazardous Chemicals in Laboratories (1910.1450)

Who: Train employees of laboratory facilities where hazardous
chemicals, or those which cause health problems in exposed
employees, are used
When: • At the time of initial assignment to a covered work area
• Before assignment to new exposure situations
• Refresher training as determined by employer
9/14 Training–25
Trainer Qualifications
Do trainers need to have certain qualifications or certification to conduct employee

training?
OSHA’s general industry standards do not have any overall requirements for trainers
that would apply to every situation. If OSHA has specific requirements for trainers, they
are found in the applicable standard itself. And, even when OSHA does specify require-
ments for trainers, they generally do not include any type of formal certification or
completion of a certain training program.
The following are examples of OSHA standards that specify requirements for trainers:
• Bloodborne Pathogens (1910.1030(g)(2)(vii)) – Requires that the person
conducting the training be knowledgeable in the subject matter covered by the
elements contained in the training program as it relates to the workplace that
the training will address.
• Powered Industrial Trucks (1910.178(l)(2)(iii)) – Requires that all operator
training and evaluation be conducted by persons who have the knowledge,
training, and experience to train powered industrial truck operators and evalu-
ate their competence.
• Hazardous Waste Operations and Emergency Response (1910.120(e)(5),
(p)(7)(iii), and (q)(7)) – Includes qualifications for trainers at hazardous waste
site clean-up operations; hazardous waste treatment, storage, and disposal
facilities; and operations involving emergency response to hazardous sub-
stance releases.
• Fire Brigades (1910.156(c)(1) and (c)(3)) – Requires training instructors to be
provided with training and education that is more comprehensive than that
provided to the general membership of the fire brigade, and that the quality of
the training and education program for fire brigade members is to be similar
to those conducted by certain fire training schools.
26–Training 9/14
Reserved
W/X/Y/Z–1
Reserved
2–W/X/Y/Z
REFERENCE
Table of Contents
OSHA Letters of Interpretation................................................................ 1

Glossaries ............................................................................................ 1
Glossary of Safety and Health Terms.................................................... 1
Glossary of Safety and Health Acronyms ............................................. 10
Agency Contacts................................................................................... 1
Reference–1
Reserved
2–Reference

OSHA Letters of Interpretation
Marking and width requirements for aisles in industrial operations
1972/05/15
Standard Number: 1910.22(b)
May 15, 1972
REPLY TO ATTN OF: OSHA/ARAC
SUBJECT: Compliance with Aisle Markings (Part 1910.22(b))
TO: All Area Directors
As a result of numerous calls regarding the marking and widths of aisles in industrial
operations, the following are considered to comply with the requirements:
The lines used to delineate the aisles may be any color so long as they clearly define
the area considered as aisle space. The lines may be composed of dots, square, strip
or continuous, but they too must define the aisle area.
The recommended width of aisle markings varies from 2 inches to 6 inches; therefore,
any width 2 inches or more is considered acceptable.
The recommended width of aisles is at least 3 feet wider than the largest equipment to
be utilized, or a minimum of 4 feet.
R. A. Wendell
Assistant Regional Administrator
for Compliance
[Corrected April 17, 2009]
OSHA Letters of Interpretation–1

Color of exit signs
1972/09/14
Standard Number: 1910.37; 1910.37(b)(6)
September 14, 1972
Mr. H. W. Somershoe
Executive Vice President
DAP Inc.
P.O. Box 277
Dayton, Ohio 45401
Dear Mr. Somershoe:
In regard to your letter of September 7, 1972, exit markings in places of employment are
covered under [29 CFR 1910.37(b)(6)] of the OSHA Standards (Federal Register, May 29,
1971 [Revised November 7, 2002 67 FR 67949-67965]). [Subparagraph (b)] in the discus-
sion of exit sign marking and distinctive lighting for exits have no prohibition against the
color red. Any color, or color combinations, that is readily visible or distinctive in appearance
on exit signs is acceptable to OSHA. It is possible that local building codes may requires a
certain color, but our standards do not.
We trust that this information will be of assistance to you.
Sincerely,
PATRICK J. HOMMY
CSHO, Standards
[Corrected 2/6/2004]
2–OSHA Letters of Interpretation

Training and competency of aerial lift operators
1975/07/17
Standard Number: 1910.67
July 17 1975
Mr. Robert E. Schumacher
General Manager
High Plains Insurance, Inc.
P.O. Box 100
Hays, Kansas 67601
Dear Mr. Schumacher:
This is in response to your letter of May 21, 1975, regarding aerial ladders or booms.
Enclosed is a copy of 29 CFR 1910.67, Vehicle-Mounted Elevating and Rotating Work
Platforms amendment, that was published in the Federal Register of March 6, 1975. This
amendment gives you the answer to your questions.
There is nothing in the wording of 1910.67 that requires the employer to certify and des-
ignate an operator to another party. Employers have the responsibility of devising methods
to train their operators in the safe operation of aerial lifts. Only competent and careful
operators should be assigned these duties. The operator shall be trained in safe operations
and made familiar with the manufacturer’s manual, especially those parts which relate to
operation, maintenance, and safety of aerial devices.
If I can be of any further assistance, please feel free to contact me.
Sincerely,
Janet H. Sprickman
Acting Chief
Division of Occupational
Safety Programming

Disabled (vision impaired) forklift operators
1976/10/20
October 20, 1976
Mr. Walter Chapman, Director,
Safety/Security
Marion Power Shovel Company, Inc.
617 W. Center Street
Post Office Box 505
Marion, Ohio 43302
RE: Your letter dated September 22, 1976 - OSHA 1910.178
Dear Mr. Chapman:
Your letter refers to our standard 1910.178(a)(2). This paragraph deals with design and
construction requirements for powered industrial trucks, not with operator qualifications.
Our standards contain only minor reference to operator qualifications. In [1910.178(l)(1)(i)]
you will read, “Only trained and authorized operators shall be permitted to operate a pow-
ered industrial truck.”(Correction 02/16/99) [“The employer shall ensure that each power
industrial truck operator is competent to operate a powered industrial truck safely, as dem-
onstrated by the successful completion of the training and evaluation specified in this
paragraph (l).”] No mention is made of vision requirements. The ANSI Standard B56.1-1969
in Section 6 reads, “Operators of powered industrial trucks shall be physically qualified. An
examination should be made on an annual basis and include such things as field of vision,
hearing, depth perception, and reaction timing.”
[This document was edited on 12/22/00 to strike information that no longer reflects
current OSHA policy.]
While OSHA did not adopt this requirement, it merits your consideration. People with only
one eye do not generally have good depth perception; this could be a most important and
critical matter in some industrial operations. You, as an employer, must determine if full
vision is mandatory in your operations. We suggest you consult with your company’s medi-
cal department.
In closing we remind you that the standard does not apply to vehicles intended primarily for
earth moving or over-the-road hauling. Please contact us if we can be of further service.
Very truly yours,
Nicholas DiArchangel
Acting Regional Administrator
for Occupational Safety and Health
cc: Wash., D.C.

Aisles and passageways
1977/02/14
Date: February 14, 1977
MEMORANDUM FOR: Donald E. MacKenzie, Acting Director
Office of Field Coordination and Experimental Programs
SUBJECT: 29 CFR 1910.22(b)(2), Aisles and Passageways
ATTENTION: Maureen Kelleher
REFERENCES: Hal Bingham
This is in response to your inquiry concerning issuance of citations where there are no
painted markings of permanent aisles and passageways for dirt floors or floors covered with
sand or dust.
The wording of the standard, 29 CFR 1910.22(b)(2), that aisles and passageways be
appropriately marked, does not require marking by painted yellow lines only. Painted yellow
lines are usually recognized as the most convenient and inexpensive way to mark aisles
and passageways since the lines normally last several years without maintenance or
repainting. Dirt floors or floors having continuous concentrations of sand or dust would
render the application of painted floor markings infeasible and impractical, especially in
foundries. Other appropriate methods such as marking pillars, powder stripping, flags, traffic
cones, barrels and many other devices are considered appropriate as long as recognition
of such is included in the vehicle operator and employee training programs. However, where
the need exists and there are no appropriate markings, citations will be issued.
Richard P. Wilson, Deputy Director
Federal Compliance and State Programs

A tie-off system is acceptable where a standard guardrails are not

feasible
1980/05/13
Standard Number: 1910.23(c)(1)
May 13, 1980
Mr. Paul M. Osborne
General Operations Manager
Eller Outdoor Advertising Co. of Colorado
Division of Combined Communications Corp.
P.O. Box 1468
Denver, Colorado 80201
Dear Mr. Osborne:
This is in response to your letter dated April 23, 1980, requesting a permanent variance from
Section 1926.104(b) - Tie-Off Systems, of the Occupational Safety and Health Regulations
for Construction.
Your request should have been made under Section 1910.23(c)(1) of the General Industry
Standards concerning the guarding of open-sided floors, platforms, and runways. Your
operation is covered under the General Industry Standards rather than the Construction
Regulations. The General Industry Standards do not have a section pertaining to tie-off
systems, therefore, a variance is not required.
OSHA has determined that when a standard guardrail is not feasible because it would result
in impairment of the work being performed alternate protection may be provided for employ-
ees. A tie-off system is acceptable as a method of meeting the intent of Section
1910.23(c)(1). A copy of OSHA Directive Number 75-40 is enclosed for your guidance.
Our technical staff has reviewed the sketch of the poster panel submitted with your appli-
cation. It has been determined that the eye bolts should be relocated to a position that would
be at least waist high for the employee’s safety belt and lanyard. Waist high should be the
lowest location in use to reduce the distance an employee would fall from the platform in the
event of an accident.
Affected employees should be notified of this decision in the same manner they were
notified of your request for a variance.
No further action will be taken on your request for a variance. If I can be of further assis-
tance, please contact my office at (202) 523-7144.
Sincerely,
James J. Concannon Director
Office of Variance Determinations

Meat grinder standards
1982/01/28
January 28, 1982
Mr. James H. Tourtelotte
Robinson, Donovan, Madden & Berry, P.C.
Attorneys at Law
1500 Main Street - Suite 1400
Springfield, Massachusetts 01115
Dear Mr. Tourtelotte:
Thank you for your letter of November 30, 1981, regarding meat grinder standards. Please
accept our apology for the delay in response.
The Occupational Safety and Health Administration enforces a performance safety standard
pertinent to all machines used by employees. The General Industry Standard 29 CFR
1910.212, general requirements for all machines, is applicable to meat grinders (copy
enclosed). Paragraph .212(a)(1) requires that one or more methods of machine guarding be
provided to protect the operator and other employees from the hazards created by the point
of operation, such as ingoing nip points. Paragraph .212(a)(3)(ii) further requires that the
point of operation of machines whose operation exposes an employee to injury shall be
guarded.
Under the Occupational Safety and Health Act, the employer is responsible for the proper
safeguarding of equipment used by employees, whether or not the manufacturer of the
equipment provides adequate safeguards.
If we may be of further assistance, please call or write.
Sincerely,
John K. Barto Chief,
Division of Occupational Safety Programming

The use of a safety chain in lieu of a gate
1982/02/12
February 12, 1982
Philip H. Clarkson, P.E.
Manager, Structural Engineering
Lockwood Greene Engineers, Inc.
Post Office Box 491
Spartanburg, South Carolina 29304
Dear Mr. Clarkson:
This is in response to your letter of January 19, 1982, concerning the use of a safety chain
in lieu of a gate. Your letter addressed to the Atlanta Regional Office was forwarded to this
office for response.
29 CFR 1910.23(a)(2) does require ladderway openings to be provided with a swinging gate
or offset passage. However, if in fact the safety chains used for top and intermediate rails
afford employees protection “at least as effective as” the swinging gate, the safety chains
would be adequate and noted as a de minimis violation.
Under OSHA’s operating procedures there are provisions whereby a de minimis violation
will be noted during the inspection for employers who have not met the exact requirements
and/or specifications of the standards. A de minimis violation is one which has no direct or
immediate relationship to the safety or health of employees, carries no penalties and does
not require abatement of the violation. A copy of the directive on this subject is enclosed for
your information.
If I may be of further assistance, please call or write.
Sincerely,
John K. Barto
Chief,
Division of Occupational Safety Programming

Precautions when barricading of drill and pile rigs is not possible
1983/06/03
Standard Number: 1926.550(a)(9)
June 3, 1983
Mr. Francis P. Dorcey
The Millgard Corporation
P.O. Box 2248
12822 Stark Road
Livonia, Michigan 48151
Dear Mr. Dorcey:
This is in response to your letter of May 11, 1983, requesting a clarification of 29 CFR
1926.550(a)(9) as it applies to drilling and pile driving operations.
29 CFR 1926.550(a)(9) does apply to drill and pile rigs, however, OSHA recognizes that it
may be functionally impossible to barricade such equipment if it is constantly moving in the
performance of the work operation. Whenever compliance with a standard is impossible,
OSHA requires employers to take all available alternative precautions. Your safety program,
including (1) Pointing out the swing radius danger by posting signs, (2) Instructing employ-
ees in the danger of swinging counterweights, (3)Instructing employees in the danger of rig
pinch points, (4) Instructing the operators to swing only on signals from the foreman or the
designated Signal Man, and (5) requiring employees not to move a rig until they know the
area is clear would appear to implement adequate alternative precautionary measures.
This interpretation is based on Federal standards. However, you should be aware that
Section 18 of the Occupational Safety and Health Act allows States to assume responsibility
for enforcement of their own occupational safety and health programs. There are currently
twenty-four such programs in operation. These states must enforce standards that are
either identical or at least effective as the Federal standards. A list of the State’s plan States
is enclosed.
If I may be of further assistance, please feel free to contact me.
Sincerely,
Bruce Hillenbrand
Acting Director, Federal Compliance
and State Programs

Exits must not be locked or obstructed
1991/12/19
Standard Number: 1910.36(d)
December 19, 1991
MEMORANDUM FOR: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMMING
FROM: LINDA R. ANKU
REGIONAL ADMINISTRATOR
SUBJECT: OBSTRUCTED EXIT PERMITTED BY USDA
The purpose of this memorandum is to bring to your attention an incident that may indicate
that some USDA inspectors are permitting means of egress to be obstructed based on a
requirement that certain doors be “sealed”. The doors are “sealed” to prevent contamination
of the food. As a result of the fire in North Carolina, USDA inspectors were instructed to
insure that “sealed” doors were not padlocked. An employer that had a padlock on a
“sealed” door, that was an exit, was required to remove it by a USDA inspector but was
permitted to insert a bolt through the hasp where the padlock had been. The bolt would have
had to be manually removed before the door could be opened.
The bolt inserted through the hasp had a hole in it through which a wire was run. The wire
could only be removed if it was broken, which would indicate that the “sealed” door had
been opened. The USDA inspector did not realize that the method used to seal the door was
still not in compliance with OSHA regulations as he only had been instructed to insure that
such doors were not padlocked.
The USDA was contacted and advised of the problem and they took immediate steps to
have it corrected. However, the incident raises serious concerns as to whether this is
occurring at other USDA regulated facilities. The USDA representative indicated that they
are to receive safety training from OSHA in the near future but until then there could be a
problem with obstructed exits. We would suggest that consideration be given to immediately
contacting the USDA and urging them to advise their inspectors as to what constitutes an
obstructed exit.
This incident occurred at:
M.H.B. Inc. dba Harrisons Meatpacking
1207 Almond Street
Williamsport, Pa. 17702
If you need any additional information regarding the preceding, please contact John McFee
at FTS 596-1201.

Permit-Required Confined Spaces: metal container curing ovens
1993/11/15
Standard Number: 1910.146(c)(7); 1910.147; 1910.146(b)
November 15, 1993
Mr. Trey Mayfield
Can Manufacturers Institute
1625 Massachusetts Avenue, N.W.
Washington, D.C. 20036
Dear Mr. Mayfield:
This is in response to your letter of August 30, concerning the Permit-Required Confined
Space (PRCS) standard (1910.146) and a work practice in your Industry. Specifically you
are seeking confirmation that the work practices outlined in your letter would constitute
compliance with 1910.146(c)(7). Please accept our apology for the delay in this response.
Metal container curing ovens meet the definition of a PRCS. Therefore, employee entry into
such spaces must be conducted in compliance with the PRCS standard. An employer who
eliminates the hazards from a permit space, as provided by paragraph (c)(7) of the stan-
dard, can reclassify that space as a non-permit confined space. That reclassification, which
would remain in effect as long as the hazards remain eliminated, would allow employers to
have employees enter the curing ovens without implementing a permit space program.
Item 1 of your letter addresses using Lockout-Tagout (1910.147) procedures to eliminate
the hazards of moving machinery and natural gas. We agree that through the application of
1910.147, the hazards of stored energy and moving machinery would be eliminated. We do
not agree that lockout-tagout would eliminate the natural gas hazard. Hazard elimination in
that case would require one of the techniques (blanking, blinding, misaligning or removing
sections of lines or pipe, and double block and bleed system) referenced in the definition of
“isolation” (see paragraph (b) of 1910.146).
Item 2 indicates that a cool down time is allotted so that the latent heat of the oven does not
create a heat exposure hazard. We concur with the cool down practice to eliminate this heat
stress potential. However, we suggest the actual job safety practice indicate a maximum
oven temperature allowable or other measurable parameter (period of time) allotted before
entry.
Item 3 describes your process for verifying that there are no atmospheric hazards. The
standard does not specify a duration of time over which verification monitoring must be
done. However, we do not see a problem with the documented baseline monitoring program
being conducted over an 8 hour period of time as long as the employer can prove that
atmospheric hazards have been eliminated from the ovens before an employee enters.
Verification monitoring with the ventilation system off will be needed to establish that atmo-
spheric hazards have been eliminated. OSHA agrees that spot air monitoring for
atmospheric monitoring for atmospheric hazards is not necessarily required by paragraph
(c)(7), however, it is the most appropriate way of determining that atmospheric hazards
have not manifested themselves.

Item 4 prohibiting solvents or welding during non-permit entries is a sound practice and
should be continued.
Should you have further questions concerning your request please contact Mr. Don
Kallstrom in the Office of General Industry Compliance Assistance (202) 219-8031.
Sincerely,
Roger A. Clark, Director
Directorate of Compliance Programs

OSHA Policy Regarding Voluntary Rescue Activities
1994/07/26
Standard Number: 1903.14(f)
July 26, 1994
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
FROM: JAMES W. STANLEY
DEPUTY ASSISTANT SECRETARY
SUBJECT: OSHA Policy Regarding Voluntarily
Rescue Activities
The purpose of this memorandum is to reiterate OSHA’s citation policy regarding employers
whose employees perform or attempt to perform rescues of individuals in life-threatening
danger. If an employer has met his or her responsibilities as outlined in the attached
memorandum, that employer shall not be cited for an employee’s voluntary heroic actions.
Attachment
March 31, 1994
MEMORANDUM FOR: Regional Administrators
THROUGH: LEO CAREY, Director
Office of Field Programs
FROM: H. BERRIEN ZETTLER, Deputy Director
SUBJECT: Policy Regarding Voluntary Rescue
Activities
The Occupational Safety and Health Administration (OSHA) is aware that conditions may
arise at workplaces where employees are exposed to life-threatening situations; and fellow
employees may enter a danger zone in an attempt to rescue the imperiled workers, thereby
exposing themselves to mortal danger. Such situations too often lead to the death of the
would be rescuer as well as the person originally in danger. It is not the intent of OSHA to
interfere with or to regulate an individual’s choice to place himself/herself heroically at risk
to save the life of another person. OSHA believes, however, that it is appropriate to provide
instruction to the field offices as to the agency’s citation policy toward employers whose
employees perform or attempt to perform rescues of individuals in life-threatening danger.
Individuals who place themselves at risk to save the life of another person fall into two
groups: those who have an occupational responsibility to rescue others and those who do
not. The safety and health of persons designated for service on rescue teams or directed to
perform rescue activities in the course of carrying out the duties of their jobs are the
responsibility of the employer, and citations are appropriate for violations causing hazards

to which such employees are exposed. Citations could be issued, for example, if appropri-
ate rescue equipment is not provided or if an employee is sent into danger without adequate
personal protective equipment.
Employer responsibility for employees with no occupational rescue obligation depends on
the work environment. Should an occasion arise where the employees of such an employer
expose themselves in an attempt to rescue a fellow worker, normally no citation shall be
issued to the employer, whether or not the rescue is successful. An exception to this rule is
discussed in the following paragraph.
In work environments where there is little or no foreseeable likelihood of a life-threatening
emergency, the employer would not be required to provide either rescue equipment or
training and would not be subject to citation. On the other hand, there are certain work-
place operations where the likelihood of life-threatening accidents is relatively high,
such as confined spaces, hazardous waste and emergency response situations,
working on or near unguarded energized power conductors, trenches and excava-
tions, diving operations and working around or over water. OSHA believes that
employers with employees in these situations, who may be faced with a rescue decision,
have the obligation to implement an accident prevention program which will address how
such emergencies should be addressed by his employees and to ensure that each such
employee is trained to recognize the hazards inherent in rescue efforts and the associated
risks to potential rescuers not trained in or properly equipped for rescue operations.
Although this does not necessarily mean that the employer is required to provide rescue
equipment (except where required by a specific standard, e.g., 1926.106) or to train the
employees in proper rescue procedures unless he intends them to conduct rescues, cir-
cumstances may arise where the employer may be under an obligation to supply such
equipment, e.g., where he knows that conditions at a site are dangerous and that his
employees are likely to attempt rescues. It does mean that he must instruct employees in
the dangers attendant upon rescuing persons without such training and equipment and that
they are not to attempt such rescues in the absence of proper equipment and training.
OSHA bases its understanding on the fact that in construction, employers are required to
have an accident prevention program (29 CFR 1926.20(b)(l)) and a training program
addressing the specific hazards which their employees are likely to encounter on their
worksites (29 CFR 1926.21). In general industry, although there is no overall training
requirement, specific training requirements exist relating to hazard communication, permit-
required confined spaces, hazardous waste and emergency response, the use of
respiratory protection and other standards.
If an employer has trained his or her employees as outlined in this document, that employer
will not be cited for an employee’s voluntary heroic actions (whether or not they are
successful).
This memorandum establishes OSHA’s citation policy regarding voluntary rescue activities
until the development of a directive is completed. This memorandum should be shared with
the State Program designees, who are urged to adopt a similar policy.

103D CONGRESS
1ST SESSION
S._______________
____________________________
IN THE SENATE OF THE UNITED STATES
Mr. KEMPTHORNE (for himself. ______________________________
______________________________________________________
_______________) introduced the following bill: which
was read twice and referred to the Committee on
____________________________
____________________________
A BILL
To provide an exemption from citation by the Secretary
of Labor under the Occupational Safety and Health Act
to employers of individuals who perform rescues of
individuals in imminent danger as a result of an
accident, and for other purposes.
1 Be it enacted by the Senate and House of Representatives
2 of the United States America in Congress assembled,
3 SECTION 1. SHORT TITLE.
4 This Act may be cited as the “Heroic Exemptions to
5 Regulation Under the Occupational Safety and Health Act” (HERO
6 Act).
1 SEC. 2. FINDINGS AND PURPOSES.
2 (a) FINDINGS.--Congress finds that--
3 (1) the strict application of existing Occupational
4 Safety and Health Administration regulations
5 requires the issuance of a citation to an employer in
6 a circumstance in which an employee of such employer
7 has voluntarily acted in a heroic manner to
8 rescue individuals from imminent harm during work
9 hours;
10 (2) application of such regulations to employers
11 in such circumstance causes hardships to those employers

12 who are responsible for individuals who perform

13 heroic acts to save individuals from imminent
14 harm;
15 (3) strict application of such regulations in such
16 circumstance penalizes employers as a result of the
17 necessary time lost and legal fees incurred to defend
18 against such citations; and
19 (4) in order to save employers the cost of un-necessary
20 enforcement an exemption from the issuance
21 of a citation to an employer under such circumstance
22 is appropriate.
23 (b) PURPOSE.--It is the purpose of this Act to provide
24 a complete exemption from the issuance of citations
25 by the Secretary of Labor under section 9 of the Occupational
26 Safety and Health Act (29 U.5.C 658) to employers
1 of individuals who voluntarily perform rescues of persons
2 in imminent danger.
3 SEC. 3. DEFINITION.
4 For purposes of this Act, the term “imminent harm”
5 means the existence of any condition or practice that could
6 reasonably be expected to cause death or serious physical
7 harm before such condition or practice can be abated.
8 SEC. 4. CITATIONS.
9 Section 9 Of the Occupational Safety and Health Act
10 (29 U.S.C. 658) is amended by adding at the end the following
11 subsection:
12 “(d) No citation may be issued under this section
13 with respect to a voluntary rescue by an employer’s employee
14 of an individual in imminent harm.”.

Enforcement of fall protection on moving stock
1996/10/18
Standard Number: 1910 Subpart D; 1910.132(d)
October 18, 1996
MEMORANDUM REGIONAL ADMINISTRATORS
FOR:
FROM: JOHN B. MILES, JR, DIRECTOR [DIRECTORATE OF
ENFORCEMENT PROGRAMS]
SUBJECT: Enforcement of Fall Protection on Moving Stock
The Directorate has been asked by the National Grain and Food Association (NGFA) to
clarify the Agency’s enforcement policy relating to fall hazards from the tops of “rolling
stock,” such as rail tank or hopper cars and tank or hopper trucks or trailers. The reason for
this request is that the NGFA is concerned that the Agency may inappropriately issue
citations for fall hazards from such equipment. Part of the NGFA’s concern is that inspectors
from the Federal Grain Inspection Service allegedly have indicated to grain handling com-
panies that they are unwilling to place themselves in situations which potentially violate
OSHA regulations, thereby, risking citation.
The contents of rolling stock, when located in yards, on sidings or similar locations, fre-
quently have to be sampled to ensure continued grain quality. Without Federal grain
inspection services, no grain can be moved to market. Employees or inspectors may walk
along the tops of the cars while they go from car to car to obtain samples.
The current fall protection standard in general industry (Subpart D) does not specifically
address fall hazards from the tops of rolling stock. The new proposed fall protection stan-
dard, 55 Fed. Reg. 13360, explicitly excludes rolling stock from coverage. The enforcement
policy of the Agency, consequently, is that falls from rolling stock also will not be cited under
Subpart D.
Additionally, it would not be appropriate to use the personal protection equipment standard,
29 CFR 1910.132(d), to cite exposure to fall hazards from the tops of rolling stock, unless
employees are working atop stock that is positioned inside of or contiguous to a building or
other structure where the installation of fall protection is feasible. In such cases, fall pro-
tection systems often can be and, in fact, are used in many facilities in the industry.
Apart from the safety obligations of grain handling companies toward their employees, the
U.S. Department of Agriculture is obligated under Section 1960.9, as an employer, to
provide its employees, the grain inspectors, a place of employment that is free from rec-
ognized hazards that are causing or are likely to cause death or serious harm, in addition
to complying with OSHA’s regulations.
The General Duty Clause, Section 5(a)(1) of the OSHAct, requires an employer to provide
employees with a workplace that is free from hazards that are recognized by the employer’s
industry and that are likely to cause death or serious physical harm. Thus, where feasible

means exist to eliminate or materially reduce the hazard, a citation can be issued for a
Section 5(a)(1) violation. For example, in the case of inclement weather such as icy con-
ditions or heavy rains and winds, both the grain handling company and the U.S. Department
of Agriculture are responsible for guarding against workplace hazards. In addition to making
a determination as to whether the tops of the rail cars are safe and free from hazards to
allow employees to perform their duties, the employers should also make an assessment of
the employee’s physical ability to perform the job and ensure that employees have received
adequate training to perform the job safely.

Powered industrial truck modifications and approval
1997/04/11
April 11, 1997
Mr. Kenneth J. Yotz
Senior Vice President
Environmental, Management
and Training Systems, Inc.
919 St Andrews Circle
Geneva, Illinois 60134-2995
Dear Mr.Yotz:
This is in further response to your letter of January 12, requesting clarification of the
Occupational Safety and Health Administration (OSHA) Powered Industrial Truck standard,
29 CFR 1910.178(a)(4). I regret the delay in responding to your. Your questions have been
included in this response for clarity.
1. Clearly, OSHA (and ANSI) requires that modifications and additions which affect the
capacity and safe operation require prior written manufacturers’ approval [29 CFR
1910.178(a)(4)]. What measures are available to an employer if the manufacturer is no
longer in business?
Reply: 29 CFR 1910.178(a)(4) requires that “Modifications and additions which affect
the capacity and safe operation shall not be performed by the customer or user without
manufacturers prior written approval. Capacity, operation, and maintenance instruction
plates, tags, or decals shall be changed accordingly.” In the event that a powered
industrial truck manufacturer has been sold to another company and is no longer in
business, the user or customer must contact the purchasing company to request
approval. In the event that the original powered industrial truck manufacturer is no
longer in business and has not been purchased by another entity, the user or customer
would be required to contact a Qualified Registered Professional Engineer for approval
of such modifications and additions.
2. Experience has demonstrated that manufacturers of forklifts and attachments are
reluctant to provide written approval due to liability considerations. Are any other
options available to employers who wish to use manufactured or fabricated attach-
ments with a forklift? Are a safety analysis and marking of the forklift by the employer
acceptable? If so, must the analysis be performed by a registered engineer.
Reply: With regard to compliance with 1910.178(a)(4), employers must seek written
approval from powered industrial truck manufacturers when modifications and addi-
tions affect the capacity and safe operation. However, if no response or a negative
response is received from the manufacturer, OSHA will accept a written approval of the
modification/addition from a Qualified Registered Professional Engineer. A Qualified
Registered Professional Engineer must perform a safety analysis and address any
safety and/or structural issues contained in the manufacturer&39;s negative response

prior to granting approval. Machine data plates must be changed accordingly.

3. Some companies purchase or fabricate booms and other lifting devices for use with
forklifts. Essentially, they can be utilized to make the forklift a mobile crane. It seems
that I can vaguely recall an old OSHA case decided by an ALJ which addressed this
issue, but I do not recall the outcome. If these devices are used, does the OSHA crane
standard apply or does any ANSI standard apply which could be referenced by OSHA
to demonstrate knowledge under Section 5(a)(1) of the OSH Act?
Reply: The use of such lifting devices usually affects the capacity and safe operation
of a powered industrial truck, therefore the user would be required to request approval
from the manufacturer for such modification and addition to the powered industrial
truck. OSHA will evaluate what standard would be particularly applicable to forklifts
modified with booms or other devices on a case-by-case basis. Also, a June 1996,
OSHA Hazard Information Bulletin regarding this subject is enclosed for your informa-
tion.
The OSHA, powered industrial truck standard was adopted from the B56 consensus stan-
dard. You may wish to contact the ASME B56 Committee for a further request of
interpretation regarding requirements for modifications and additions to trucks, which affect
capacity and safe operation, at the following address:
Secretary of the B56 Committee
ASME
345 East 47th Street
New York, New York 10017
We appreciate your interest in occupational safety and health. If we can be of further
assistance, please [contact the office of General Industry Enforcement at (202) 693-1850].
Sincerely,
John B. Miles, Jr., Director

OSHA’s Methylene Chloride Standard
1997/06/27
June 27, 1997
The Honorable Bud Cramer
U.S. House of Representatives
2416 Rayburn Building
Washington, DC 20515-0105
Dear Congressman Cramer:
Thank you for your letter of January 16, 1997, regarding the Occupational Safety and Health
Administration’s (OSHA) Methylene Chloride (MC) Standard. We wish to assure you that
OSHA is aware of the concerns you raise regarding the impacts of the MC rule and has
addressed these concerns in the preamble to the final rule and the Final Economic Analysis.
We would like to take this opportunity to clarify some misimpressions being raised about the
risks of MC exposure and the methods available to reduce those risks to the U.S. workforce.
Please accept our apology for the delay in this response.
The OSHA MC rulemaking was initiated in 1986 when the Agency published an Advance
Notice of Proposed Rulemaking in response to a petition from the United Auto Workers
(joined by several other unions) to regulate MC because it was shown to be carcinogenic in
laboratory animals. In 1991, OSHA published a Notice of Proposed Rulemaking which
included a proposed 8-hour time-weighted average (TWA) permissible exposure limit (PEL)
of 25 ppm, a short-term exposure limit of 125 ppm and ancillary provisions covering expo-
sure monitoring, medical surveillance, regulated areas, etc. In 1992, the Agency convened
informal public hearings on the proposed standard in Washington, DC and San Francisco,
CA. In addition, the rulemaking record was opened several times to receive public comment
on feasibility and risk assessment issues.
The final MC rule (published in the Federal Register on January 10, 1997 (62 FR 1493)) is
based on careful evaluation of all available information, including information submitted to
the record by representatives of small businesses. OSHA’s rulemaking record (now in
excess of 48,000 pages of information) contains extensive data regarding the feasibility of
compliance with the final rule, including information on substitutes for MC, modifications to
control or process equipment and alterations in work practices. Many of these feasible
methods of compliance are as simple and common-sensical as providing adequate venti-
lation, or covering tanks and containers when not in use. Data in the record indicates that
the final MC regulation is feasible in all affected industries. OSHA must base its findings on
its rulemaking record and must promulgate a regulation that is technologically and eco-
nomically feasible for all affected industries.
OSHA has been particularly concerned with the ability of small businesses to comply with
the MC standard. Therefore the Agency has streamlined requirements to reduce potential
economic and paperwork burdens on such employers, including extending compliance
deadlines for employers with fewer than 20 employees. Many of the actions taken by OSHA

to reduce the potential compliance burdens in the final MC rule were the direct result of input
to the MC rulemaking by small employers.
OSHA has thoroughly evaluated all information submitted to the record concerning the
health effects of MC, including cancer, and has used this information to conduct a quanti-
tative risk assessment using physiologically-based pharmacokinetic (PBPK) information
and cutting-edge statistical methodologies. Indeed, industry groups have repeatedly asked
OSHA to adopt a PBPK approach to its MC risk assessment; OSHA has determined that the
data base (notably including the new data submitted by the Halogenated Solvents Industry
Alliance (HSIA)) is now sufficiently reliable and detailed to support such an approach. The
Agency has determined that the risks to workers exposed to MC at levels greater than 25
ppm as an 8-hour TWA greatly exceed the level of risk deemed significant by the Supreme
Court and would be clearly unacceptable. The evidence that a limit of 50 ppm would be
severely inadequate to protect workers includes a wealth of animal bioassay data, numer-
ous studies detailing the human metabolism of MC to carcinogenic products, risk
assessment based on these data, and several epidemiologic studies that suggest an
elevated risk of biliary cancer and astrocytic brain cancer in MC-exposed workers.
After completing its analyses, OSHA briefed the scientific staff from the Environmental
Protection Agency, the Food and Drug Administration, the National Institute for Environ-
mental Health Sciences, and the Consumer Product Safety Commission on the Agency’s
analysis of the submitted studies and OSHA’s revised risk assessment. The professionals
at these meetings agreed with OSHA’s characterization of the risks posed by MC and
specifically praised the Agency for incorporating the specific type of additional information
(PBPK data) that the HSIA and others had advocated be used.
The PBPK data and model structures used as the basis of OSHA’s final risk assessment
were available in the record for review and comment. Several PBPK models were submitted
to the record and elicited comments during the MC rulemaking. In the course of drafting the
final risk assessment, OSHA reanalyzed all of the available and appropriate data in the
record, but did not revise the underlying assumptions upon which its preliminary risk
assessment and the PBPK-based assessments submitted to the Agency relied. In October
1995, OSHA re-opened the rulemaking record specifically for the purpose of incorporating
mechanistic data submitted to the Agency by the HSIA. OSHA requested comments on how
that data should be used in characterizing the risks of MC. Based on its analysis of the data
and comments received, OSHA made the appropriate changes to its risk assessment. In
addition, the rulemaking record was opened serval times to receive public comment on the
key issues raised on feasibility and MC risk assessment.
OSHA’s final MC risk assessment estimates that at lifetime occupational exposure to 25
ppm, the additional risk of dying of cancer is 3.6 deaths per 1000 workers. OSHA’s goal,
where technologically and economically feasible, is to reduce cancer risks to below 1 death
per 1000, consistent with Supreme Court guidance. Other agencies with statutory obliga-
tions to protect the general population aim for levels of protection more than 100 times
greater than the level used by OSHA. Although the risks at 25 ppm are significant, the
Agency is currently constrained from reducing the PEL to below 25 ppm due to a lack of
definitive evidence documenting the feasibility of lower limits. OSHA has promulgated the
standard at 25 ppm, in order to reduce risks and because the Agency has determined that
25 ppm is technologically and economically feasible across industry sectors.

Thank you for bringing your concerns to our attention. Your interest in occupational safety
and health is greatly appreciated.
Sincerely,
Adam M. Finkel, Sc.D.
Director
Health Standards Programs
January 16, 1997 Mr. Joseph Dear
Assistant Secretary
Occupational Health & Safety Administration
Third Street and Constitution Avenue, NW
Washington, DC 20210
Dear Mr. Dear:
I am writing about the Occupational Safety and Health Administration (OSHA) workplace
standard for methylene chloride which I understand OSHA intends to issue shortly. I have
constituents who have indicated they would have significant problems in complying with a
25 parts-per-million limit. I would appreciate the opportunity to explore my concerns with you
before the final standard is issued.
Specifically, I understand the risk assessment and the economic analyses that are the basis
for the rule have changed significantly over the past few months. OSHA should give the
public an opportunity to comment on the revised scientific and economic analyses before
taking final action on the methylene chloride standard, unless there is a statutory or judicial
deadline that precludes OSHA from taking this action. This would also allow OSHA to have
the benefit of participating in the interagency characterization of the potential risk posed by
methylene chloride under the EPA guidelines, expected to be completed in 1997.
In addition, the Small Business Regulatory Enforcement fairness Act requires the OSHA
seek congressional review of the methylene chloride standard. If the methylene chloride
standard is issued without giving the public an opportunity to review and comment on the
revised scientific and economic analyses, this review may be extensive. I urge you to take
the time to address valid constituent concerns, so there can be widespread congressional
support for OSHA’s final action.
Sincerely,
Bud Cramer
Member of Congress

Aerial lift regulations; fall protection for scissor lifts
1998/07/21
Standard Number: 1926.451; 1926.451(g)(1)(vii); 1926.452(w); 1926.453
July 21, 1998
Dennis Vance
Safety Specialist
Safety Services
711 Low Gap Road
Princeton, WV 24740
Dear Mr. Vance:
RE: 1926.451(g); 1926.452(w);1926.453; 1926.502(d); CPL 2-1.23; ANSI A92.2; ANSI
A92.6; scissors lift.
This is in response to your letter of May 27 to the Occupational Safety and Health Admin-
istration (OSHA) in which you asked whether an employee working from a scissors lift
equipped with guardrails needed to wear a “safety harness.” You further expressed concern
for the confusion created by OSHA’s scaffold standard and its directive, CPL 2.112 (sic).
Please accept our apology for the delay in responding to this inquiry and for any previously
submitted requests.
We recognize that there is confusion regarding scissors lifts and the appropriate standards
governing such equipment. The confusion stems from the way OSHA’s directive is worded.
In CPL 2-1.23, titled “Inspection Procedures for Enforcing Subpart L, Scaffolds Used in
Construction - 29 CFR 1926.450-454,” dated January 7, 1997, the statement in paragraph
K.9.b states that scissors lifts are addressed by 1926.453, Aerial Lifts, and not by
1926.452(w), Mobile Scaffolds. The directive should have more clearly indicated that only
aerial lifts meeting the design and construction of the American National Standards Institute
(ANSI) A92.2, Vehicle Mounted Elevating and Rotating Work Platforms, are addressed by
1926.453 since the coverage of that section is specifically limited to such lifts. All other types
of mobile lifts would be covered by the specific requirements at 1926.452(w) and/or the
general requirements of 1926.451. Please note, however, that if an employer is in full
compliance with the requirements of the relevant document of the ANSI A92 series, OSHA
would consider that compliance as providing an appropriate degree of safety for employees.
In regards to your specific question, when working from an elevated scissors lift (ANSI
A92.6 series), a worker need only be protected from falling by a properly designed and
maintained guardrail system. 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. The general scaffolding fall protection provision found in 1926.451(g)(1)(vii) reads
in part, “[f]or all scaffolds not otherwise specified in this section, each employee shall be
protected by the use of personal fall arrest systems or guardrails systems.”

If you require any further assistance, please do not hesitate to contact us again by writing
to OSHA-Directorate of Construction, Office of Construction Standards and Compliance
Assistance, Room N3621, 200 Constitution Ave., NW, Washington, D.C. 20210.
Sincerely,
Russell B. Swanson, Director
Directorate of Construction

Powered industrial truck training content, certification, and record

maintenance
1999/10/01
Standard Number: 1910.178(l); 1926.602(c); 1926.602(d)
October 1, 1999
Larry Edginton
Director, Safety & Health
International Union of Operating Engineers
1125 Seventeenth Street NW
Washington, D.C. 20036
Re: Powered Industrial Truck Training: §§1910.178(l) and 1926.602(c) and (d)
Dear Mr. Edginton:
Thank you for your letter dated May 18 to the Occupational Safety and Health Administra-
tion (OSHA) regarding the new requirements for powered industrial truck (PIT) operator
training in §1910.178(l) (under §1926.602(d), those requirements are applicable to employ-
ers engaged in construction). As you state in the letter, many International Union of
Operating Engineers (IUOE) members may work for several employers over the course of
a year. The letter indicates that providing or evaluating operator training presents practical
problems for construction industry employers. You explain that IUOE locals are implement-
ing standardized PIT training programs throughout the U.S. in response to the December 1,
1998, final rule, and you ask several questions regarding implementation of the standard.
Equipment covered by the Powered Industrial Truck standard
The construction standard for powered industrial trucks can be found in subpart O, 29 CFR
1926.602(c). Section 1926.602(c) incorporates the consensus standard ANSI B56.1 by
reference and, therefore, has the same scope as the ANSI standard. Section
1926.602(c)(1)(vi), which was not changed by the new PIT training rule (volume 63 of the
Federal Register on page 66255), states:
“All industrial trucks in use shall meet the applicable requirements of design, construction,
stability, inspection, testing, maintenance, and operation, as defined in American National
Standards Institute B56.1, 1969, Safety Standards for Powered Industrial Trucks.”
The PIT training rule references not only ANSI B56.1 (the revised title is “ASME B56.1”), but
further clarifies that the final rule applies to the vehicles covered by other volumes of
consensus standards, including ASME B56.6, Rough Terrain Forklift Trucks (63 FR 66255).
Your letter quotes the definition of a rough-terrain forklift taken from the American Society
of Mechanical Engineers (ASME) standard B56.6, and you ask whether the standard only
applies to various types of equipment used on construction job sites that conform to that
definition. It reads in part, “....a wheeled-type truck designed primarily as a fork truck with a
vertical mast and/or pivoted boom, variable reach or of fixed length, which may be equipped
with attachments....” That definition describes rough-terrain forklifts that are used primarily

in construction; however, this should not be considered an all inclusive list for equipment
covered by subpart O.
Neither consensus standard referenced in subpart O (ANSI/ASME B56.1 and ASME B56.6)
directly addresses whether the equipment must have a vertical mast and/or a pivoted boom
to be covered by the standard. Subpart O does not define rough-terrain forklifts, nor does
the December 1, 1998, final rule. However, the preamble lists various types of vehicles that
are covered by the rule (63 FR 66239), of which several do not have vertical masts or
pivoted booms, such as low lift platform trucks and motorized hand trucks. So, neither a
vertical mast nor a pivoted boom is a prerequisite for coverage under the standard.
Training program content
The new training provisions of §1926.602(d) can be found in §1910.178(l). Section
1910.178(l)(3) addresses training program content and requires that employees receive
training in various truck-related topics, workplace-related topics and in the requirements of
this section of the rule. It further lists sub-topics that should be included, unless a particular
topic is not relevant to the type of vehicle or workplace.
Your letter lists four subjects included in the IUOE Local’s PIT training, and you ask if
construction employers are required to provide any additional training for employees. Your
list did not include training in the standard itself, as required in §1910.178(l)(3)(iii). In
addition, employers may need to ensure that additional training on site-specific or truck-
specific matters is provided. One such example might be instruction on the safe operation
of trucks with specialized attachments so that the operator understands the restrictions and
limitations of the vehicle with those attachments. However, if the employee already has
been trained to operate with those attachments, then the employer need not duplicate that
training.
Paragraph 4.19 of ASME B56.1-1993 (the current edition of that consensus standard)
contains specific operator training topics that were the basis for the topics in paragraph (l)(3)
of the final rule. A training program that covers these topics would comply with (l)(3) (for the
complete text of paragraph 4.19, see the preamble at 63 FR 66240-66241).
You also ask whether employees trained before December 1, 1999, the date for compliance
with the standard, need to have their performance evaluated according to the 3-year anni-
versary of their training or the December 1 compliance date. Paragraph (l)(4)(iii) requires
that an evaluation of each powered industrial truck operator’s performance be conducted
once every three years to ensure that the employee has retained and continues to use the
knowledge and skills necessary to operation the vehicle safely. The date of the previous
training controls the time frame for the next evaluation, not the compliance date for the
standard.
Refresher training time frame
The PIT provisions governing refresher training and evaluations are located in §1910.178(l)
(4). This section requires refresher training to be provided to ensure that the operator
continues to have the knowledge and skills to operate the powered industrial truck safely.
You note that this section specifies no time frame in which refresher training, prompted by
the list of triggers in paragraph (l)(4(ii), is to occur. You ask if the employee must receive this
training before he/she is allowed to continue operating the PIT. The standard’s performance
language does not set an absolute requirement that an operator cease to work immediately

following an incident. This allows employers flexibility when considering the severity of the
incident that triggered the need for retraining.
The final rule provides a performance-oriented and cost-effective approach to refresher
training. The type, amount, and timing of refresher training depends on several factors, such
as the equipment and terrain characteristics, nature of the unsafe act, and the potential for
an accident or other incidents of unsafe acts or violations of §1910.178 to occur or reoccur.
Operator certification
Employers are required to certify that each operator has been trained and evaluated. As
required by §1910.178(l)(6), the certification shall include the name of the operator, the date
of the training, the date of the evaluation, and the identity of the person(s) performing the
training or evaluation.
You ask if employers can rely solely on evaluation and certification provided by third party
trainers. OSHA did not specify that the employer, or supervisor, or any other particular
person, must conduct the training and evaluation, only that the training and evaluation be
conducted by a person who is qualified. The training criteria are sufficiently detailed so that
employers and professional trainers can provide adequate training. The preamble indicates
that qualified third-party trainers could provide the training (63 FR 66,252). This was envi-
sioned as an important tool for meeting the requirements of the standard. As long as the
employer has a reasonable basis to believe that the third-party trainer is qualified and has
a program that meets the requirements of the standard, it can rely on that trainer to conduct
the training and evaluation of employees and can certify that these employees have been
trained. However, as mentioned earlier, the employer may need to provide additional train-
ing on site-specific or truck-specific matters.
Maintaining Records
You further ask who must maintain the training and certification records. Paragraph (l)(6)
does not specify who must maintain the records; however, the employer is ultimately
responsible for ensuring the availability of these records. Third-party trainers who agree to
maintain the records would also need to ensure their immediate availability to the employer.
If you require further assistance, please do not hesitate to contact us again by writing to:
OSHA-Directorate of Construction, Office of Construction Standards and Compliance Assis-
tance, Room N3468, 200 Constitution Ave., NW, Washington, D.C. 20210.
Sincerely,

Employee hand placement on and around suspended crane loads
1999/10/21
October 21, 1999
Ms. Yvonne Horton
Oak Ridge National Laboratory
P.O. Box 2008
Oak Ridge, TN 37831-6103
RE: 29 CFR 1926.550(a)(19)
Dear Ms. Horton:
This is in response to your April 15, 1999, letter in which you ask a question relating the
requirements of 29 CFR 1926.550 (Cranes, Derricks, Hoists, Elevators and Conveyors) with
respect to employees working near or under suspended loads.
Question 1: Under what circumstances may employees guide a suspended load by
placing their hands on it? Is it permissible for employees to place their hands on a
load that is seven feet high if they stand to the side of, and not under, the load?
Answer: Employees may stand beside a suspended load and guide it into place with
their hands when, in view of the height of the load, actual and potential swing of the
load and trip hazards, the employees are not at risk of being struck by the load if it
were to fall.
29 CFR 1926.550(a)(19) states “All employees shall be kept clear of loads about to be lifted
and of suspended loads.” When employees are guiding suspended loads into place,
employees can get near the load and assist in guiding the load in, but at no time shall the
employee be at risk of being struck by the load if it were to fall or swing out of control. If an
employee needs to guide a load that is being lowered, but the load is at a height that would
place the employee at risk of becoming off balance while reaching for the load, tripping and
falling under it, or is otherwise at risk of being struck by the load if it were to fall or swing out
of control, the employee must use tag lines or other means to guide it. An employee may
stand aside a load that is seven feet high and guide it with his or her hands only where these
risk factors are absent.
Question 2: Does the standard permit employees to put their hands under a raised
load to place blocks?
Answer: When it is infeasible for an employee to keep his or her hands out from
under a raised load while placing block under it, the employer shall ensure that the
load is not released until the employee’s hands are removed from under the load.
If blocks need to be placed under a suspended load, and conditions exist that prevent the
employer from using blocks long enough to allow employees to keep their hands out from
under the load, employees may, using appropriate care, place their hands under the load to
set the blocks. When using crawler, truck and locomotive cranes, Section 5-3.3 (Signals) of

the American National Standards Institute (ANSI) B30.5-1968, which is incorporated into the
OSHA standard by §1926.550 (b)(2), requires that the crane operator not release or lower
the load further until the operator receives a signal to do so. ANSI signal requirements for
other types of cranes are incorporated by §1926.550 (a)(4). At no time shall an employee
place their hands under a load that is being lowered.
If you require any further assistance, please do not hesitate to contact us again by writing
to: Directorate of Construction - OSHA Office of Construction Standard and Compliance
Assistance, Room N3468, 200 Constitution Avenue N.W., Washington D.C. 20210.
Sincerely,

Fall protection requirements for fixed and portable ladders in

construction
2000/01/13
Standard Number: 1926.1053(a)(19); 1926.1053(a)(18); 1926.502(d)(16)(iii); 1926.1050(b)
January 13, 2000
Mr. Peter G. Chaney
Mechanical Contractors Association of America, Inc.
1385 Piccard Drive
Rockville, MD 20850-4340
RE: [29 CFR 1926] Subpart X
Dear Mr. Chaney:
This is in response to your May 26, 1999, letter in which you ask for clarification of several
issues relating to the use of fall protection when working from ladders during construction
work. You specifically ask if OSHA has any requirements for the use of fall protection when
working from ladders at heights greater than six feet. We apologize for the lateness of this
response.
Fixed ladders: fall protection must be provided for employees climbing or working on
fixed ladders above 24 feet.
29 CFR 1926.1053(a)(19) states that fall protection must be provided whenever the length
of climb on a fixed ladder equals or exceeds 24 feet. A fixed ladder is “a ladder that cannot
be readily moved or carried because it is an integral part of a building or structure”
(§1926.1050(b)). Also, even if the length of climb is less than 24 feet, under
§1926.1053(a)(18), cages, wells, ladder safety devices, or self-retracting lifelines must be
provided where the top of the fixed ladder is greater than 24 feet above lower levels.
Portable ladders: fall protection is not required for employees climbing or working on
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.
You note that a number of general contractors in Georgia “are attempting to require personal
fall arrest systems for their subcontractors working on ladders 6 feet or higher.” Although the
OSHA standards do not require fall protection for workers on fixed ladders below 24 feet or
on portable ladders, we encourage employers to provide additional protection.
Personal Fall Arrest Systems can be set up to limit arrested falls to less then 15 feet.
In your letter you assert that personal fall arrest systems will not arrest a fall from an
elevation lower than 15 feet. When anchored above the worker, a typical personal fall arrest
system will arrest a fall in 6 feet or less. Using a six foot lanyard, a fall distance as high as
approximately 14 feet would result only if the system were anchored at the worker’s feet, as
explained below.

Several factors must be considered in determining how much distance will be needed for a
fall arrest system to work — to prevent the worker from contacting the next lower level. First,
under §1926.502(d)(16)(iii), a personal fall arrest system must prevent the employee from
contacting the level below. A 6 foot lanyard that incorporates a shock absorbing system may
have a total extension of up to about 9½ feet before a fall is completely arrested. Because
the lanyard is attached to the body harness at a point that is more than half-way up the body,
an additional distance of about 3-4 feet must be added to assure that no part of the
employee’s body makes contact with the surface.
Second, under §1926.502(d)(16)(iii), a personal fall arrest system must limit an employee’s
free fall to not more than six feet. “Free fall” is defined in the standard as “the vertical
displacement of the fall arrest attachment point on the employee’s ... body harness between
onset of the fall and just before the system begins to apply force to arrest the fall.” If a 6 foot
lanyard is rigged to an anchorage at floor level, the total free fall would be the sum of the
vertical distance between the attachment point on the body harness and the floor (usually
4 to 4½ feet) plus the length of the lanyard (6 feet in this example), which totals about 10
feet. That means that the use of a 6 foot lanyard, rigged to an anchorage at the worker’s feet
would result in a free fall in excess of the 6 foot limit. That would only be allowed where the
employer cannot provide a more suitable anchorage or other form of fall protection.
Where a person is standing on the surface to which the arrest system is anchored, if a fall
occurred, the person would first fall the distance of the anchor point to the location of the
lanyard attachment on the body harness, which is usually approximately 4½ feet (this will
vary with the height of the worker). The worker would then fall the length of the lanyard,
which in this example is 6 feet. Finally, assuming a shock absorbing system were incorpo-
rated into the lanyard, the worker would fall another 3½ feet if the full length of the shock
absorber was used. The total of these distances is about 14 feet.
Remember that in many situations fall distances can be eliminated altogether by using
restraint systems, which are set-up to prevent the worker from stepping past the walking/
working surface edge. These systems are often attached to catenary lines. In work involving
the construction of a “leading edge” (where the work surface itself is being constructed and
advances as the work progresses), the catenary line is periodically advanced to keep pace
with the advancing work. Retractable lanyards are another option that can often be used.
OSHA’s decision not to require the use of personal fall arrest systems in other
situations while working on ladders.
Apart from the above requirements, you ask why OSHA did not require the use of personal
fall arrest equipment whenever an employee is working 15 feet or higher on a ladder (you
do not specify whether you are asking this with respect to fixed or portable ladders or both).
You suggest that this may have been due to fall arrest systems causing a “greater hazard.”
The preamble to the standard does not explain why fall arrest equipment was not mandated
for situations other than those specified in §1926.1053(a)(18) and 1926.1053(a)(19). How-
ever, the use of personal fall protection does not generally result in a greater hazard.
Working without fall protection continues to be one of the leading causes of fatalities in the
construction industry.

OSHA jurisdiction in Georgia

You also ask for a statement that Georgia is under the jurisdiction of Federal OSHA; it is.
If you need additional information, please contact us by fax at: U.S. Department of Labor,
OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax #
202-693-1689. You can also contact us by mail at the above office, Room N3468, 200
Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our
receiving correspondence by mail.
Sincerely,

Applicability of 1910.178 to earth moving equipment and skid steer

loaders
2000/03/07
Standard Number: 1910.178(a)
March 7, 2000
Ms. Michele Corbin
Pennsylvania Landscape & Nursery Association
1707 South Cameron Street
Harrisburg, Pennsylvania 17104
Dear Ms. Corbin:
Thank you for your February 4, 2000 letter to the Occupational Safety and Health Admin-
istration’s (OSHA’s) [Directorate of Enforcement Programs (DEP)]. Your letter has been
referred to the [Office of General Industry Enforcement (GIE)] for answers to your questions
regarding operator training for powered industrial trucks. Your specific questions have been
restated below for clarity.
Question 1. If a vehicle that is intended primarily for earth moving utilizes removable forks,
would the vehicle fall under the Powered Industrial Truck Regulations?
Response. The preamble to the Final Rule, found on page 66255 of Federal Register Vol.
63, No. 230, clearly states that equipment that was designed to move earth but has been
modified to accept forks is not covered be the final rule. Therefore, if your vehicle is
designed as earth moving equipment, it would not be considered a powered industrial truck
within the scope of §1910.178.
Question 2. Would a skid steer be considered an earth moving vehicle?
Response. A skid steer loader designed, manufactured, and used in accordance with
Society of Automotive Engineers (SAE) J1057 would be not be considered a powered
industrial truck under §1910.178. However, vertical mast skid steer loaders are designed as
powered industrial trucks meeting ANSI B56.6 Rough Terrain Forklift Trucks. These skid
steers would be considered powered industrial trucks under §1910.178.
Question 3. Is there a percentage of time that the removable forks must be used on the
vehicle to qualify for the Powered Industrial Truck Regulations?
Response. As stated above, the design of the vehicle is the determining factor, rather than
the time of use aspect.

Thank you for your interest in occupational safety and health. We hope you find this infor-
mation helpful. Please be aware that OSHA’s enforcement guidance is subject to periodic
review and clarification, amplification, or correction. Such guidance could also be affected
by subsequent rulemaking. In the future, should you wish to verify that the guidance pro-
vided herein remains current, you may consult OSHA’s website at http://www.osha.gov. If
you have any further questions, please feel free to contact the [Office of General Industry
Enforcement] at (202) 693-1850.
Sincerely,
Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

Minimum width of means of egress; redesignation of 1910.1020
2000/04/27
Standard Number: 1910.37; 1910.36(g)(2); 1910.36; 1910.36(b); 1910.24(d); 1910.1020
April 27, 2000
Mr. Gregory W. Faeth
President
Safety Consulting & Training Services
PO Box 1718
Fairfield, IA 52556
Dear Mr. Faeth:
Thank you for your December 28, 1999 to the Occupational Safety and Health Administra-
tion’s (OSHA’s) Directorate of Compliance Programs. Please be aware that this response
may not be applicable to any scenario not delineated within your original correspondence.
You had specific questions regarding Fixed Industrial Stairs, 29 CFR §1910.24, and the
redesignation of the Access to Employee Exposure and Medical Records Standard, 29
CFR §1910.1020. Your questions and our reply follow.
Question #1: The OSHA [exit route] requirements, [§1910.36(g)(2)], state that the minimum
width of any way of exit access shall in no case be less than 28 inches and the OSHA stair
requirement, §1910.24(d), requires a minimum stair width of 22 inches. Is an employer out
of compliance with this [exit route] standard if the stairs are 22 inches in width?
Reply: Yes, if the stair is an [exit route] component (the exit access, the exit itself, or exit
discharge). All stairs, and other approved [exit route] components, must meet the Subpart
E, [Exit Routes] standards.1
Furthermore, in order to afford all occupants convenient facilitates for escape, the capacity
of an [exit route] (i.e., stair) for any occupied space must be appropriate to the individual
building or structure with due regard to the character of the occupancy; the number of
persons exposed; the fire protection available; and the height and type of construction of the
building or structure. [See paragraph 1910.36(b)(3).] The minimum width permitted for a
passageway used as an exit access is, according to [§1910.37(g)(2)], 28 inches; however,
most occupancies require additional width based upon the capacity of [exit route] require-
ments.
The 22 inch stair width requirement applies to both interior and exterior, fixed industrial
stairs (i.e., around machinery, tanks, and other equipment; to and from floors, platforms, or
pits) when they are used as described in the application paragraphs 1910.24(a) and (b).
Where these requirements overlap, the [Exit Routes] requirements would apply.
Question #2: Why did OSHA move §1910.20 to §1910.1020 without updating other 1910
standard references to §1910.1020? There are many references to §1910.20 and the only
corrected reference is in the newer Respiratory Protection, §1910.134, Standard. For
example, paragraph 1910.120(f)(8)(i) incorrectly directs a reader to §1910.20 instead of
§1910.1020.

Reply: In redesignating §1910.20 as §1910.1020, OSHA has simply moved the standard
from Subpart C to Subpart Z of the Part 1910 - Occupational Safety and Health Standards.
We have not changed or modified the standard language. Your observation correctly iden-
tifies OSHA’s omission to change the §1910.20 reference language. Our [Directorate of
Standards and Guidance] is currently working on a correction notice to rectify this incon-
sistency. This notice should be published in the Federal Register and become effective this
year.
mation helpful. Please be aware that the enforcement guidance contained in this response
represents the views of OSHA at the time the letter was written based on the facts of an
individual case, question, or scenario and is subject to periodic review and clarification,
amplification, or correction. It could also be affected by subsequent rulemaking; past inter-
pretations may no longer be applicable. In the future, should you wish to verify that the
guidance provided herein remains current, you may consult OSHA’s website at http://
www.osha.gov. If you have any further questions, please feel free to contact the [Office of
General Industry Enforcement] at (202) 693-1850.
Sincerely,
[Directorate of Enforcement Programs]
1
The source for the performance-oriented standard is the National Fire Protection Asso-
ciation Life Safety Code (NFPA 101-1970); it is current OSHA’s policy to use this consensus
standard as a reference source for clarification purposes. In the past, OSHA has used the
Life Safety Code (the Code) as an aid in interpreting Subpart E and we intend to continue
to rely on the NFPA Life Safety Code (NFPA 101-2000) and other consensus standards as
guidance in implementing performance-oriented requirements.
[This document was edited on 02/05/2004 to strike information that no longer reflects
current OSHA policy. 29 CFR 1910 Subpart E was revised on November 7, 2002 and
incorporates compliance with NFPA 101-2000 at 1910.35.]

Foundation requirements for scaffolds; competent person

qualifications for assessing foundations
2000/08/01
Standard Number: 1926.451(c)(1)(iii); 1926.451(c)(2); 1926.451(c)(2)(i); 1926.451(f)(3);
1926.451(f)(7); 1926.450
August 1, 2000
Mr. Donald J. Kemp
Hardy Construction Company
P.O. Box 1203
Billings, MT 59103
Subject: Scaffold Foundation and Competent Person Knowledge, Training and Inspecting,
1926.450, 1926.451(c)(1)(iii), 1926.451(c)(2), 1926.451(c)(2)(i), 1926.451(f)(3),
1926.451(f)(7)
Dear Mr. Kemp:
This is in response to your letter dated January 28, 2000, addressed to the Occupational
Safety and Health Administration requesting an interpretation of the scaffold standard, 29
CFR 1926 Subpart L. Specifically, your questions deal with the following issues: what is
considered a “firm foundation” for a scaffold, and who is responsible for determining the
adequacy of the foundation?
Question 1: Section 1926.451(c)(2) states: “supported scaffold poles, legs, posts, frames,
and uprights shall bear on base plates and mud sills or other adequate foundation.” OSHA’s
Directive Number CPL 2-1.23 states: “A concrete slab would be considered a firm founda-
tion, and therefore mud sills would not be necessary.” What is the definition of “other
adequate foundation?” What are some of the other options for providing an adequate firm
foundation?
Answer: An adequate foundation is one that, like base plates on mud sills, will prevent the
scaffold from settling into the ground. The purpose of the mud sill under the scaffold base
plate is to uniformly distribute the scaffold load over a larger area than that distributed by the
base plate alone, thereby reducing the loading on the ground beneath the base plates. The
scaffold baseplates and mudsills increase the area where the downward forces of the
scaffold are transmitted. The scaffold load is transferred from the uprights to the base plates
and then to the mud sills or other adequate foundation from the scaffold legs, which must
show minimal or negligible settlement under a full scaffold loading to be adequate.
The standard recognizes that certain foundations may be of adequate firmness to support
a scaffold without the use of mud sills. Generally, the adequacy of a foundation to support
a scaffold cannot be determined in the abstract because of the numerous factors which may
exist at a work site. Concrete is the lone exception to this rule, which, because of its
structural properties and strength, OSHA has determined constitutes a firm foundation.
Section 1926.451(c)(2)(i) goes on to require that: “footings shall be level, sound, rigid, and
capable of supporting the loaded scaffold without settling or displacement.” The preamble

to Subpart L (volume 61 of the Federal Register at page 46043, August 30, 1996) states:
“Every scaffold must stand on a firm footing if it is to withstand the load that employees,
equipment and materials place on it.” In short, an adequate foundation is one that supports
the load of the supported scaffold, materials and workers without collapse or shifting of one
component or the entire scaffold.
Daily site conditions of scaffold footing can change with the temperature, rain, snow, etc. It
is important to plan the erection, use and dismantling of the scaffold to address all possible
conditions including the site’s soil conditions.
Question 2: Would soil compacted to 96 - 99.9% density, then frozen in the cold of winter
be considered adequate? What about cold asphalt paving (in winter)? Hot asphalt paving (in
summer)? Wood decking? Compacted gravel roads?
Answer: As mentioned previously a site’s conditions and soil types have varying degrees
of load bearing ability. Also, the load bearing ability of the materials you mention varies.
Therefore, it is impossible to provide exact answers under the conditions you propose
because of the multitude of other variables that may exist. We discuss some of the problems
in each of your examples below. In all cases a competent person must inspect and approve
the foundation (daily).
a. Compacted Soils & Then Frozen - Compacted soils, as with all soils, swell and heave
due to moisture content or water contained within the soil. This creates a dangerous
situation during the freeze/thaw cycle (which can occur in the course of a day) causing
the soil to swell or settle and may not result in a level rigid footing. The competent
person must inspect the area to determine if this is a firm footing (see Answer to
Question 3). Then this must be inspected when conditions change, such as sunny
conditions, warming temperatures, etc.
b. Cold asphalt paving (winter) - Asphalt has minimal compressive strength, even when
cold, and especially when applied. By itself it is not normally a useable foundation
material.
c. Hot asphalt paving (summer) - This type of asphalt (top coat) is soft when placed and
then compacted with rollers. It is generally applied as a thin coat over a base coat and
takes several days to achieve its designed strength. Only the base coat gives the
asphalt compressive strength.1
d. Wood decking - This may lend itself for use as a foundation. However, an evaluation of
the deck for its maximum allowable loading would be required, since the decking or
deck structure could fail under a full scaffold load. The competent person would need
to know the individual scaffold base plate loading and if each one is below the maxi-
mum allowable deck loading.
A light weight supported scaffold could be used on wood decking when the competent
person has determined the structure would support the scaffold and its entire load.
e. Compacted Gravel Roads - This type of road surface may have adequate strength but
the material does not provide a smooth surface. Additionally, there is no material
cohesion; during a storm the material can wash away under the scaffold base plates.
In each of the examples cited, some type of settlement or displacement could occur when
used without mud sills. The foundation where the scaffold would be erected must be evalu-
ated in the pre-job planning. This determination is extremely important to the erection, use

and dismantling of the scaffold. The determination must be made by a competent person
with the knowledge of the type of scaffold, the expected live and dead loads, and the
weather conditions for the area.
Question 3: Who is responsible for determining whether a foundation is adequate? What
qualifications must that person have?
Answer: Under §1926.451(c)(1)(iii), the employer must have a designated competent per-
son make this determination. A competent person is defined in §1926.450 as one who is
capable of identifying existing and predictable hazards in the surroundings or work in the
surroundings or working conditions which are unsanitary, hazardous, or dangerous to
employees, and who has authorization to take prompt corrective measures to eliminate
them. With respect to the adequacy of foundations, the competent person must be knowl-
edgeable about foundation surfaces and soils, and able to recognize conditions such as a
soil wash under a scaffold leg.
Question 4: How do employees get to be competent to determine an adequate scaffold
foundation?
Answer: The competent person is designated by the employer and has the authorization to
take prompt corrective measures to eliminate hazards. In making that determination, the
employer should inquire into the individual’s work credentials and experience. The pre-
amble to Subpart L (volume 61 of the Federal Register at page 46,059, Aug. 30, 1996) gives
the following example of what is required to become a “competent person” on scaffolding.
A ’competent person’ for the purpose of this provision must have had specific training
in and be knowledgable about the structural integrity of scaffolds as well as the degree
of maintenance needed to maintain them. The competent person must also be able to
evaluate the effects of occurrences such as, a dropped load, or a truck backing into a
support leg that could damage a scaffold. In addition, the competent person must be
knowledgeable about the requirements of this standard. A competent person must
have training or knowledge in these areas in order to identify and correct hazards
encountered in scaffold work.
In the situation you have described, the competent person must be able to assess the load
of employees, equipment and materials placed on the scaffold’s foundation. While an engi-
neering degree is not a prerequisite, that assessment normally requires some technical
skills, and the competent person making that determination would have to have those skills.
If you need additional information, please contact us by fax at: U.S. Department of Labor,
OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax #
202-693-1689. You can also contact us by mail at the above office, Room N3468, 200
Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our
Sincerely,

ANSI Z358.1 guidance for complying with 1910.151(c) citation policy

for eyewashes and showers
2002/04/18
Standard Number: 1910.151(c)
April 18, 2002
Mr. Paul Hagmann
5877 Sand Drive
West Bend, Wisconsin 53095
Dear Mr. Hagmann:
Thank you for your October 2, 2001 letter to the Occupational Safety and Health Adminis-
tration’s (OSHA’s) Directorate of Compliance Programs. You requested clarification of
OSHA standard 29 CFR 1910.151 (Medical Services and First Aid). This letter constitutes
OSHA’s interpretation only of the requirements discussed and may not be applicable to any
questions not delineated within your original correspondence. Your questions have been
restated below for clarity. We apologize for the delay in your response.
Question 1: Will OSHA cite a facility for not following the recommendations as stated in
ANSI standard Z358.1-1990? Specifically, will an OSHA inspector cite a facility for not
supplying tempered water to an emergency eyewash and shower?
Reply: Paragraph (c) of 29 CFR 1910.151 requires the employer to provide suitable facili-
ties for quick drenching or flushing of the eyes and body when employees may be exposed
to injurious corrosive materials. ANSI standards become mandatory OSHA standards only
when, and if, they are adopted by OSHA; ANSI Z358.1 was not adopted by OSHA. In
comparison with the OSHA standard at 29 CFR 1910.151(c), however, ANSI Z358.1 pro-
vides detailed information regarding the installation and operation of emergency eyewash
and shower equipment. OSHA, therefore, has often referred employers to ANSI Z358.1 as
a source of guidance for protecting employees who may be exposed to injurious corrosive
materials.
As you may know, 29 CFR 1910.151(c) does not provide specific instruction regarding the
installation and operation of emergency eyewash and shower equipment. Therefore, it is the
employer’s responsibility to assess the particular conditions related to the eyewash/shower
unit, such as water temperature, to ensure that the eyewash/shower unit provides suitable
protection against caustic chemicals/materials to which employees may be exposed.
Question 2: Would the citation (in the situation described above) be written under 29 CFR
1910.151 or under the General Duty Clause, Section 5(a)(1)?
Reply: Since OSHA has a standard related to drenching/flushing facilities, any citation for
the failure to provide suitable drenching/flushing facilities must be issued pursuant to 29
CFR 1910.151(c).
Question 3: While reading product literature on emergency shower units, it stated that 30
gpm was fairly standard among drench showers; are there specific requirements for the rate
of flow for an emergency eyewash or shower unit?

Reply: OSHA has adopted no specific requirements regarding flow rates for drenching/
flushing facilities. ANSI Z358.1 provides detailed information regarding the installation and
operation of emergency eyewash and shower equipment, including the requirements for
flow rate. Section 4.1 of ANSI Z358.1 specifies that emergency shower heads shall be
capable of delivering a minimum of 75.7 liters per minute (20 gpm) of flushing fluid at a
velocity low enough to be non-injurious to the user. A sufficient volume of flushing fluid shall
be available to supply the flow rate for a minimum fifteen minute period.
Question 4: If OSHA is using the ANSI standard Z358.1-1990 for the basis of the OSHA
standard 1910.151, doesn’t OSHA need to make the ANSI standard available to the general
public and/or industry? Where can I obtain a copy of the ANSI standard Z358.1-1990?
Reply: You may obtain copies of ANSI standards by contacting ANSI at:
American National Standards Institute, Inc.
11 West 42nd Street
New York, New York 10036
Phone: (212) 642-4900
mation helpful. OSHA requirements are set by statute, standards and regulations. Our
interpretation letters explain these requirements and how they apply to particular circum-
stances, but they cannot create additional employer obligations. This letter constitutes
OSHA’s interpretation of the requirements discussed. Note that our enforcement guidance
may be affected by changes to OSHA rules. Also, from time to time we update our guidance
in response to new information. To keep apprised of such developments, you can consult
OSHA’s website at http://www.osha.gov. If you have any further questions, please feel free
to contact the Office of General Industry Compliance Assistance at (202) 693-1850.
Sincerely,

Clarification of “potential atmospheric hazard” when reclassifying a

PRCS as a non-permit required confined space
2005/12/02
Standard Number: 1910.146(b); 1910.146(c)(7); 1910.146(c)(7)(i)
December 2, 2005
Ms. Laura Johnson
Assistant Director
Iowa - Illinois Safety Council
8013 Douglas Avenue
Urbandale, Iowa 50322-2453
Dear Ms. Johnson:
Thank you for your August 2, 2005, letter to the Occupational Safety and Health Adminis-
tration’s (OSHA) Peoria Area Office. Your letter has been referred to the Directorate of
Enforcement Program’s (DEP) Office of General Industry Enforcement for an answer to
your questions regarding compliance with OSHA’s Permit-required Confined Spaces Stan-
dard, 29 CFR 1910.146. Your scenario and questions have been restated below for clarity.
Scenario: Employees must enter a permit-required confined space (PRCS) to perform
maintenance work on mechanical apparatus. The enclosure is a circular concrete wall
approximately 10 feet in height, tapering outward to the top and 25 feet in diameter. The
enclosure sits on top of a concrete cooling tower structure and houses a large fan. The top
of the enclosure is completely open to the atmosphere. Below the enclosure (approximately
10 feet) inside of the cooling tower is the “Fill Pack” through which the cooling tower water
is distributed. This fill pack is an open cellular media through a hatchway on the side of the
enclosure to access catwalks along the drive shaft and to a platform at the main gearbox in
the center of the enclosure. Complete control of hazardous energy (lockout/tagout) is per-
formed externally before entry is allowed. The only reason this confined space is considered
a permit space is because of the mechanical hazards of the fan blades and drive shaft. It
is the intent of the employer to reclassify the space to a non-permit confined space following
the regulations in 29 CFR 1910.146(c)(7) once the lockout/tagout is in place and tests to
confirm all other hazards are eliminated are completed. Atmospheric testing of the confined
space prior to entry occasionally indicates what appear to be erroneous readings for LFL
and H2S due to sensitivities of the atmospheric monitoring equipment sensors in the high
humidity area; however no sources for flammables or hydrogen sulfide exist within the
facility.
Question 1: Please provide an interpretation of potential as it is used in 29 CFR
1910.146(c)(7)(i) as it relates to hazardous atmospheres in the definitions for “Non-permit
confined space” and “Permit-required confined space” in 1910.146(b). Specifically, does a
background or ambient reading of flammable gas, below the specified 10 percent LFL,
constitute potential even when there is no source or when all sources have been isolated?
Reply: In your scenario you state that the reason the confined space is a permit space is
due to the mechanical hazards of the fan blades and drive shaft. If these are the only

hazards or potential hazards within the permit space, then why is testing of the space
conducted? Further you state that the instrumentation may give erroneous readings due to
humidity. Any erroneous readings would need to be verified as erroneous prior to entry into
the space. We would recommend that you contact the equipment manufacturer for technical
assistance in determining how to eliminate this problem. Perhaps a different type of equip-
ment could be used to atmospherically test the space during high humid conditions.
Question 2: Does documentation from a previous PRCS entry into this space that shows
that a low level LFL (5 percent) reading was present constitute potential? If so, does this
historical record continue to constitute potential even after all processes and procedures are
evaluated and it is determined that there is no source of flammables?
Reply: If there is no source of the flammable including residual contamination, then the
potential would be removed. However, any flammable which is brought into the space could
trigger a potential atmospheric hazard.
Question 3: If, subsequent to the tests that revealed the low level LFL, evaluations deter-
mine that there is no source of flammables and repeated tests showing zero LFL are
conducted, can it be accepted that there is no potential for a hazardous flammable atmo-
sphere? At what point and by what additional methods can it be accepted there is no
potential?
Reply: If the source has been truly removed, i.e. no piping, containers, residual, etc., and
the flammable material is not brought into the space by any mechanism, then there would
not be a potential atmospheric hazard for that material.
mation helpful. OSHA requirements are set by statute, standards, and regulations. Our
interpretations letters explain the requirements, and how they apply to particular circum-
may be affected by changes to OSHA rules. In addition, from time to time we update our
guidance in response to new information. To keep apprised of such developments, you can
consult OSHA’s website at http://www.osha.gov. If you have any further questions, please
feel free to contact the Office of General Industry Enforcement at (202) 693-1850.
Sincerely,
Directorate of Enforcement Programs

Machine guarding and compliance with 29 CFR 1910.219(m)
2006/05/07
Standard Number: 1910.219(m)
May 7, 2006
Mr. William K. Principe
Constangy, Brooks and Smith, LLC
Suite 2400
230 Peachtree Street, N.W.
Atlanta, GA 30303-1557
Dear Mr. Principe:
Thank you for your August 28, 2003 letter to the Occupational Safety and Health Adminis-
tration’s (OSHA’s) Office of General Industry Enforcement (GIE). Please be aware that this
response may not be applicable to any situations not delineated within your original corre-
spondence. You had specific questions regarding §1910.219(m).
Questions below have been restated for clarity.
Question: Does a guard that is held firmly in place without the use of screws or bolts, and
cannot slide out of place, or be inadvertently jostled out of place, comply with the require-
ment in §1910.219(m) that guards on mechanical power transmission apparatus be
securely fastened?
Response: Yes. The guards may be fastened by any secure method that prevents the
guard from being inadvertently dislodged or removed, including, but not limited to, such
means as screws, bolts, wing nuts and lock fasteners. OSHA would allow guards that could
be easily removed to allow maintenance or repair activities in the most efficient manner,
provided that the guard can be attached securely in place to protect employees once the
maintenance or repair activities are completed.
mation helpful. Please be aware that the enforcement guidance contained in this response
represents the views of OSHA at the time the letter was written based on the facts of an
individual case, question, or scenario and is subject to periodic review and clarification,
amplification, or correction. It could also be affected by subsequent rulemaking; past inter-
pretations may no longer be applicable. In the future, should you wish to verify that the
guidance provided herein remains current, you may consult OSHA’s website at http://
www.osha.gov. If you have any further questions, please feel free to contact the Office of
General Industry Enforcement at (202) 693-1850.
Sincerely,

Several questions regarding OSHA’s LOTO and Bakery standards 29

CFR 1910.147 and 1910.263
2006/08/25
Standard Number: 1910.147; 1910.147(a)(2)(ii); 1910.147(b); 1910.147(f)(1); 1910.212;
1910.212(a)(2); 1910.219; 1910.219(m)(1); 1910.263; 1910.263(l)(9)(ii)
August 25, 2006
Ms. Donna L. Pierce
Chambliss, Bahner & Stophel, P.C.
1000 Tallan Building
Two Union Square
Chattanooga, TN 37402
Dear Ms. Pierce:
Thank you for your March 9, 2006, letter to the Occupational Safety and Health Adminis-
tration’s (OSHA) Directorate of Enforcement Programs. You stated that you represent a
company in the baking industry with production facilities in different states and have ques-
tions regarding Federal OSHA’s Control of hazardous energy (lockout/tagout or LOTO) and
Bakery equipment standards, 29 CFR §§ 1910.147 and 1910.263, respectively.1 Your sce-
narios, paraphrased questions and our replies follow.
Scenario 1: The company has a piece of equipment that regulates temperature and humid-
ity. This equipment uses a long serpentine conveyor, approximately 61 feet long, four feet
wide and eight feet high with two levels of interlocked doors on each side. The conveyor is
composed of many individual chain driven trays that transfer the product through the equip-
ment. Periodically, the doors must be opened to observe whether the equipment is
operating properly. When the doors are opened to make this observation, safety interlocks
are by-passed, but the observer is trained never to allow a body part to pass the plane
where the door would be if closed. The observer only monitors the equipment to ensure it
is functioning properly. The observer is prohibited from performing any adjustments, repairs
or cleaning until the shutdown/lockout provisions of §1910.147 have been met.
Question 1: Is this procedure appropriate as a minor servicing exception, 29 CFR
1910.147(a)(2)(ii) or otherwise?
Question 2: If this procedure is not acceptable, would it be acceptable to have a safety
interlock override the procedure controlled through a mechanic-controlled key or some
other procedure?
Question 3: Would it be acceptable to perform the observation if the internal guards were
installed [such] that [the barrier] would prevent contact with the internal areas of the equip-
ment?
Reply: While it is not possible to conclusively determine the answer to your question without
observing this particular piece of equipment and considering the manner in which it is
situated and used, as a result of the employees’ positioning with respect to the door open-
ing, it is likely that they would be exposed to hazardous energy, such as moving parts.2

The task you describe would involve an employee observing whether the equipment is
operating properly. This activity would be considered inspecting the equipment, and there-
fore would be considered Servicing and/or maintenance as defined at 29 CFR 1910.147(b).
Although LOTO applies to servicing and maintenance, minor adjustments may be exempt
from the LOTO if the inspection process is routine, repetitive and integral to the use of the
conveyor for production purposes provided that the work is performed using alternative
measures which provide effective protection. This exemption determination must be made
on a case-by-case basis in accordance with the §1910.147(a)(2)(ii) note. As detailed in the
inspection procedure you outline,thesafety interlocks are bypassed when the doors are
opened. As a result of this bypass, LOTO would apply.
Aside from the minor servicing exception, an employer can avoid the requirements of the
LOTO standard through the use of an alternative method which eliminates employee expo-
sure to servicing and maintenance hazards — i.e., through the use of guarding methods that
meet the requirements of Machinery and Machine Guarding, 29 CFR Part 1910, Subpart O,
and Bakery Equipment, §1910.263. The internal guards you reference would satisfy this
exception if they complied with these standards.
With respect to your second question concerning the use of mechanics keys, we do not
have enough information to provide a response at this time.
Scenario 2: Another piece of equipment puts two cookies together after depositing a layer
of crème between them. This machine has to be timed perfectly to ensure proper assembly
of cookies. To successfully adjust the timing of the equipment, it must be operating when the
adjustments are made. The doors on the equipment are locked, but do not have safety
interlocks. The equipment does have internal guards to prevent insertion of fingers or hands
into the hazard area while allowing employees to make the required adjustments. Employ-
ees also occasionally use extended air nozzles to blow off excess product. Employees are
trained on the timing and cleaning processes, the safety features built into the equipment
and processes, and the potential hazards that could be created if they bypass the internal
safety features. Employees follow 1910.212, the guarding standard, but not 1910.147.
Question 4: Are these design features and safety practices satisfactory as a minor servic-
ing exception, 29 CFR 1910.147(a)(2)(ii), or otherwise?
Reply: The adjustment of a machine component’s timing mechanisms constitutes machine
servicing activity, which is covered by the LOTO standard if an employee(s) is exposed to
hazardous energy. See §1910.147(a)(2)(ii)(A) and (B). As described in the previous reply,
there is an exception for minor servicing activities which take place during normal produc-
tion operations, provided that the work is performed using alternative measures which
provide effective protection. See the 29 CFR 1910.147(a)(2)(ii) note.
In your scenario, the LOTO standard would not apply if the minor servicing exemption
applies or if the internal machine guarding method eliminates employee exposure to haz-
ardous mechanical (kinetic) energy. If this is not the case, then employee protection must
be provided, as previously described, when energization is essential (e.g., timing adjust-
ment work) — i.e., pursuant to the §1910.147(f)(1) equipment testing and positioning
provisions.
Question 5: if these design features and safety practices are not satisfactory, what stan-
dards apply?

Reply: The Machinery and machine guarding , Subpart O,standards apply to Normal pro-
duction operations — i.e., the utilization of a machine or piece of equipment to perform its
intended production functions. Activities that are necessary to prepare or maintain a piece
of equipment are not considered normal production operations and are defined as Servicing
and/or maintenance. See §1910.147(b). Section1910.147 applies to the control of hazard-
ous energy during servicing and/or maintenance of the equipment. However, it is important
to note that the Bakery equipment standard, §1910.263, also addresses the design, instal-
lation, operation, and maintenance of machinery and equipment used within a bakery,
including machine guarding requirements contained in paragraph (c).
Scenario 3: The company has a third piece of equipment with a flight chain with ears every
four or five links to ensure proper spacing and movement of the product. The chain runs in
a channel across the top of the machine and then returns back into the underside of the
machine. There are chain adjustments in the underside of the machine that require moni-
toring or adjusting occasionally. The company has trained its personnel to override the
safety switch and observe the equipment while it is running in order to determine whether
the equipment is working properly. When repairs or adjustments are actually made, lockout/
tagout (energy control procedure) is applied.
Question 6: Is this an acceptable practice?
Reply: Refer to the first reply.
Question 7: Does it make a difference how the safety switch on the guard is overridden or
if the guard is bolted shut without electrical interlocks3 that would require the employee to
use a tool to remove the door?
Reply: With respect to performance-oriented machine guarding requirements, guard design
and construction must be of such design and strength to protect workers from the machine
hazards. Guards must be affixed to the machine, where possible, and they may be fastened
by any method (e.g., bolts) that prevents the guard from being inadvertently dislodged or
removed. See §§ 1910.212(a)(2) and 1910.219(m)(1).
Scenario 4: A conveyor consists of several rollers that are four feet long and three inches
in diameter that are covered by sheet metal guards. To properly clean these rollers, the
equipment must be running. The guards are removed, and the rollers are sprayed using a
water hose as an extended tool.
Question 8: Is this an acceptable practice?
Reply: No, if the guard removal exposes the employee(s) to hazardous energy associated
with machine operation, such as moving gears, sprockets, V-belts or ingoing nip points.
Question 9: Does it matter if the equipment remains on the production line while it is
cleaned or removed to a different location for the cleaning process?
Reply: It is difficult to answer this question with the information you provided. However, the
options discussed above apply. Another option would be to lock out or tag out the conveyor,
remove the rollers and clean them in a safe area. Thereafter, the clean rollers could then be
re-installed, LOTO removed and the conveyor returned to normal production operation.
Scenario 5: Standard 1910.263(l)(9)(ii) provides that all safety devices on ovens shall be
inspected at intervals of not less than twice a month by an especially appointed, properly

instructed bakery employee, and not less than once a year by representatives of the oven
manufacturers.4
Question 10: Does the bi-weekly inspection mean that the employee must test the safety
devices in order to ensure each is functioning properly or may the employee visually inspect
the safety devices for changes from the previous inspection?
Reply: OSHA’s present Bakery equipment requirements are based upon the American
Standard Safety Code for Bakery equipment (ANSI Z50.1-1947), which included most of the
source standard’s Safety Device Testing provisions (Section 13.9.2). The OSHA standard
retained many of the source standard’s inspection requirements; however the Agency did
not include any specific testing requirements in this provision. See §1910.263(l)(9)(i) and
(ii). Therefore, the current OSHA standard does not explicitly require safety device testing.
However, these §1910.263(l)(9) general provisions for bakery oven inspections and main-
tenance are performance-oriented requirements that are intended to ensure the proper
operation of safety devices (controls). In order to prescribe a procedure that is necessary to
keep the oven safety devices functioning properly, an employer needs to base their inspec-
tion program (e.g., visual inspection requirements) on recognized and generally accepted
engineering experience, such as, but not limited to, the:
• Original equipment manufacturer (OEM) specifications/instructions; and
• Recognized and good engineering practice — e.g., Standard for Ovens and Fur-
naces, ANSI/NFPA 86-2003.
in response to new information. To keep apprised of such developments, you can consult
OSHA’s website at www.osha.gov. If you have any further questions, please feel free to
contact the Office of General Industry Enforcement at (202) 693-1850.
Sincerely,
1
Twenty-six (26) states have OSHA-approved State Plans and have adopted their own
standards and enforcement policies. For the most part, these States adopt standards that
are identical to Federal OSHA. However, some States may have adopted different stan-
dards applicable to this topic or may have different enforcement policies that are more
specific and/or more stringent.
2
Simply training the employee to stay away from hazardous machine components is not
effective alternative employee protection
3
While properly designed and maintained interlocks generally provide effective machine
guarding, §1910.212 does not require the use of interlocks.
4
The OSHA bakery equipment standard, §1910.263(l)(9)(ii) ), specifies that the annual
inspections of ovens shall be conducted by representatives of the oven manufacturer.

OSHA considers representatives of the oven manufacturer to be qualified persons who are
knowledgeable of the various safety considerations and of the safe operational character-
istics of the equipment. They may or may not be employees for the oven manufacturer.
Refer to the April 24, 1998, letter to the American Bakers Cooperative, Inc. that is posted on
the OSHA public webpage for details: http://www.osha.gov/pls/oshaweb/
owadisp.show_document?p_table=INTERPRETATIONS&p_id=22573

Locked first aid cabinets in the workplace
2007/01/23
Standard Number: 1910.151(b)
January 23, 2007
Rikki Pottebaum
Affirmed Medical Services
5591 Autumn Wynd Lane
Milford, Ohio 45150
Dear Ms. Pottebaum:
This is in further response to your November 10, 2005 letter to the Occupational Safety and
Health Administration (OSHA) requesting assistance in the interpretation of OSHA’s
requirements regarding locked first aid cabinets in the work place.
To answer your question succinctly, yes, first aid cabinets can be locked; however, they
must be readily accessible in the event of an emergency. Locking the cabinet may limit
accessibility. Title 29 CFR 1910.151(b) states: “In the absence of an infirmary, clinic, or
hospital in near proximity to the workplace which is used for the treatment of all injured
employees, a person or persons shall be adequately trained to render first aid. Adequate
first aid supplies shall be readily available.”
Employers may elect not to provide first aid services if all such services will be provided by
a hospital, infirmary, or clinic in near proximity to the workplace. If the employer has persons
who are trained in first aid, then adequate first aid supplies must be readily available for use.
These supplies need to be stored in a convenient area available for emergency access.
However, if OSHA found that an employer was relying on first aid services not provided by
a clinic, infirmary, or hospital and adequate first aid supplies were not available when
needed, then the employer would be in violation of 29 CFR 1910.151(b).
I hope you find this information helpful. Please be aware that OSHA’s enforcement guid-
ance is subject to periodic review and clarification, amplification, or correction. Such
guidance could also be affected by subsequent rulemaking. In the future, should you wish
to verify that the guidance provided herein remains current, you may consult OSHA’s
website at http://www.osha.gov If you have any further questions, please feel free to contact
the Office of General Industry Enforcement at (202) 693-1850.
Sincerely,

OSHA’s requirement to provide first aid supplies specific to the needs

of the workplace
2007/02/02
Standard Number: 1910.151; 1910.151(b)
February 2, 2007
Leanne D. Cress
P. O. Box 223
Palomar Mountain, CA 92060
Dear Ms. Cress:
Your November 23, 2006 letter to the Occupational Safety and Health Administration
(OSHA) has been referred to the Directorate of Enforcement Programs for response. This
letter constitutes OSHA’s interpretation only of the requirements discussed and may not be
applicable to any question or scenario not delineated within your original correspondence.
You asked if it was mandatory for all workplaces to provide a first aid kit.
Title 29 CFR 1910.151(b) states: “In the absence of an infirmary, clinic, or hospital in near
proximity to the workplace which is used for treatment of all injured employees, a person or
persons shall be adequately trained to render first aid. Adequate first aid supplies shall be
readily available.”
Employers may elect not to provide first aid services if all such services will be provided by
a hospital, infirmary, or clinic in near proximity to the workplace. If the employer has persons
who are trained in first aid, then adequate first aid supplies must be readily available for use.
Therefore, employers are required to provide first aid supplies that are most appropriate to
respond to incidents at their workplaces. OSHA allows employers to provide first aid sup-
plies specific to the needs of their workplace.
Although we have provided our interpretation of the federal standard, twenty-six states,
including California, operate their own OSHA-approved occupational safety and health
programs. These State-plan States adopt and enforce their own standards, which may have
different requirements from the federal standards regarding medical services and supplies.
The California Department of Industrial Relations (Cal-OSHA) administers the state plan
program. Cal-OSHA standards are accessible on the state’s website — http://
www.dir.ca.gov/occupational_safety.html. If you would like more information about
California workplace safety and health regulations, the address is as follows:
John Rea, Acting Director
California Department of Industrial Relations
1515 Clay Street, Suite 1901
Oakland, California 94612
(415) 703-5050
FAX (415) 703-5058

mation helpful. Please be aware that OSHA’s enforcement guidance is subject to periodic
review and clarification, amplification, or correction. Such guidance could also be affected
by subsequent rulemaking. In the future, should you wish to verify that the guidance pro-
vided herein remains current, you may consult OSHA’s website at http://www.osha.gov. If
you have any further questions, please feel free to contact the Office of General Industry
Enforcement at (202) 693-1850.
Sincerely,

Whether OSHA requirements prohibit working from a portable

stepladder and, if not, whether fall protection is required. 29 CFR
1926.1053(b)
2007/11/28
Standard Number: 1926; 1926.500(a)(2)(vii); 1926; 1926.1053(b); 1926.1053(b)(3);
1926.1053(b)(4); 1926.1053(b)(13); 1926 Subpart M; 1926 Subpart X
November 28, 2007
Mr. Robert S. Beisel
Safety Consultant
Project Best, Inc.
21 Armory Drive
Wheeling, WV 26003-6396
Re: Whether OSHA requirements prohibit working from a portable stepladder and, if not,
whether fall protection is required. 29 CFR 1926.1053(b).
Dear Mr. Beisel:
This is in response to your letter submitted April 27, 2006 to the Occupational Safety and
Health Administration (OSHA). Your inquiry addresses the use of portable stepladders and
fall protection. We apologize for the long delay in responding.
We have paraphrased your question as follows:
Question (1): Does 29 CFR 1926.1053(b)(4) prohibit an employee from working from a
portable stepladder?
Answer (1): Title 29 CFR 1926.1053(b), Use, provides:
***
(3) Ladders shall not be loaded beyond the maximum intended load for which they were
built, nor beyond their manufacturer’s rated capacity.
(4) Ladders shall be used only for the purpose for which they were designed.
***
(13) The top or top step of a stepladder shall not be used as a step.
***
There are no OSHA construction standards that specifically prohibit an employee from
working from a portable stepladder. However, the use of a portable ladder must comply with
the Use requirements quoted above. If working from a portable stepladder was inconsistent
with any of these provisions, such use would be prohibited. Because of the wide variety of
circumstances and ladder designs, it is not possible for us to state, as a general matter,
whether working from a portable ladder would be consistent or inconsistent with any of
these provisions.

Question (2): Is fall protection required while working from a portable stepladder?
Answer (2): In 29 CFR Part 1926 Subpart M (Fall protection), Section 1926.500(a)(2)(vii)
provides:
Requirements relating to fall protection for employees working on stairways and lad-
ders are provided in Subpart X . . .
***
There is no provision in Subpart X that requires fall protection for an employee while working
from a portable stepladder. However, if the employee will be on a surface prior to ascending
or upon exiting the ladder for which another Subpart in 1926 requires fall protection, then fall
protection would be required at such times. General requirements for fall protection can be
found at Subpart M of 29 CFR Part 1926, while requirements specific to a particular activity
or equipment can be found at its applicable Subpart in 29 CFR Part 1926.
If you need any additional information, please contact us by fax at: U.S. Department of
Labor, Directorate of Construction Office of Construction Standards and Guidance, (202)
693-1689. You may also contact us by mail at the above office, Room N3468, 200 Consti-
tution Avenue N.W., Washington, D.C. 20210; although there may be a delay in our
Sincerely,
Steven F. Witt,

Use of jack stands in the stabilization of semi-trailers
2008/04/14
Standard Number: 1910.178; 1910.178(k)(3)
April 14, 2008
Mr. Milton Pleasant
Alcoa Inc.
Reynolds Wrap Center
3041 Wilson Ave.
Louisville, KY 40211
Dear Mr. Pleasant:
Thank you for your letter of September 13, 2007, to the Occupational Safety and Health
Administration’s (OSHA’s) regional office in Atlanta, Georgia. Your letter has been for-
warded to OSHA’s Directorate of Enforcement Programs (DEP). You had a question
concerning OSHA’s Powered industrial trucks standard, 29 CFR 1910.178, and the use of
jack stands in the stabilization of semi-trailers. Your paraphrased question and our response
follow.
Question: Are two jack stands, placed one on each side of the uncoupled end of a semi-
trailer, sufficient to support the trailer and prevent it from upending during loading and
unloading using powered industrial trucks? Is one jack stand placed in the middle of the
uncoupled trailer sufficient?
Response: OSHA’s Powered industrial trucks standard, at 29 CFR 1910.178(k)(3), states
that “[f]ixed jacks may be necessary to support a semi-trailer and prevent upending during
loading or unloading when the trailer is not coupled to a tractor.” OSHA’s standard does not
specify a particular type of jack, nor the number and placement of such jacks. As noted in
the March 19, 1991, letter to Mr. Thomas Wheeler (enclosed), the language in this para-
graph is advisory rather than mandatory. However, when using portable jacks to support
semi-trailers, OSHA strongly recommends following both the trailer and the jack manufac-
turer’s instructions on the appropriate number and placement of these jacks. Additional
guidance on the loading and unloading of trailers with powered industrial trucks may be
found on OSHA’s website at
http://www.osha.gov/SLTC/poweredindustrialtrucks/loading_unloading.html.
You also enclosed a manufacturer’s brochure depicting a particular type of portable jack. As
you may know, OSHA does not approve, endorse, or promote any particular product, or
protective measure.
For your information, the State of Kentucky administers its own occupational safety and
health program under a plan approved and monitored by Federal OSHA. Therefore,
employers in the State of Kentucky must comply with State occupational safety and health
requirements. As a condition of plan approval, States are required to adopt and enforce
occupational safety and health standards that are at least as effective as those promulgated
by Federal OSHA. For the most part, Kentucky standards are identical to the Federal

standards, although Kentucky does have some additional standards with different require-
ments. If you would like further information regarding Kentucky’s occupational safety and
health requirements, you may contact the Kentucky Department of Labor at the following
address:
Steve Morrison, Executive Director
Office of Occupational Safety and Health
1047 U.S. Highway 127 S.
Suite 4
Frankfort, KY 40601
(502) 564-3070
in response to new information. To keep apprised of such developments, you may consult
OSHA’s website at http://www.osha.gov If you have any further questions, please feel free
to contact the OSHA Office of General Industry Enforcement at (202) 693-1850.
Sincerely,

Guarding of access openings to fixed ladders
2009/09/29
Standard Number: 1910.23; 1910.23(a)(2); 1910.27
September 29, 2009
MEMORANDUM REGIONAL ADMINISTRATORS
FOR:
FROM: RICHARD E. FAIRFAX, DIRECTOR
DIRECTORATE OF ENFORCEMENT PROGRAMS
SUBJECT: Guarding of Access Openings to Fixed Ladders
The purpose of this memorandum is to clarify the requirements for guarding access open-
ings to fixed ladders. Differences in the regulatory text between paragraphs 1910.23(a)(2)
and 1910.23(c)(1) and silence on this issue in paragraph 1910.23(c)(2) and in the fixed
ladder standard at 1910.27 have led to some confusion.
Openings on platforms are regulated by different paragraphs of §1910.23. Paragraph
§1910.23(a) covers floor openings, including access openings at the edge of a platform.
Paragraph §1910.23(b) covers wall openings and wall holes. Paragraph §1910.23(c) covers
the edges of open-sided floors and platforms, but not the access openings at the edge of
the platform or through the floor.
The governing requirement for the guarding of ladderway floor openings and platforms is
paragraph 1910.23(a)(2):
Every ladderway floor opening or platform shall be guarded by a standard railing with
standard toeboard on all exposed sides (except at entrance to opening), with the
passage through the railing either provided with a swinging gate or so offset that a
person cannot walk directly into the opening.
This paragraph applies to ladders that extend to another working surface, even if the ladder
attaches to the edge of the working surface or the platform, since the opening at the ladder
access point is also a floor opening. It also applies to floor openings in runways and
catwalks. All ladderway floor openings or platforms must be protected by a standard railing
except at the entrance to the opening. The passage through the railing, however, must be
protected by a swinging gate or offset so that a person cannot walk directly into the opening.
Paragraph §1910.23(c)(1) requires a standard railing on all open-sided floors or platforms
4 feet or more above floor or ground level, except at entrances to ramps, stairways, or fixed
ladders. It describes where a standard railing is required and includes an exception for the
entrance to fixed ladders. This paragraph does not, however, exempt the passage through
the railing for platforms from being protected by a gate or offset as required in paragraph
1910.23(a)(2). The intent of the exemption in paragraph (c) was to allow other than a
standard, fixed, guardrail at the entrance to a fixed ladder. Required protection for the
access openings on runways and catwalks are also included in this paragraph.

Unguarded ladderway floor openings and unguarded ladderway entrances on all surfaces
should be cited under section 1910.23(a)(2).
If you need any additional information or clarification on this memorandum, please contact
the Office of General Industry Enforcement at (202) 693-1850.

Reserved

Glossaries
Glossary of Safety and Health Terms
Act The Williams-Steiger Occupational Safety and Health Act of

1970. (84 Stat. 1590 et seq., 29 U.S.C. 651 et seq.)
Action level The exposure level (concentration in the air) at which OSHA
regulations to protect employees take effect. Exposure at or
above action level is termed occupational exposure.
Acute effect An adverse effect on the human body with symptoms of high
severity coming quickly to a crisis.
Acute exposure An exposure to a toxic substance which occurs in a short or
single time period.
Acute toxicity Acute effects resulting from a single dose of, or exposure to, a
substance. Originally used to denote effects in experimental
animals.
Adjacent spaces When describing confined space, those spaces bordering a
subject space in all directions, including all points of contact,
corners, diagonals, decks, tank tops, and bulkheads.
Aerosol A solid particle or liquid droplet suspended in the air. An aerosol
is larger than a molecule and can be filtered from the air.
Affected An employee who works in an area in which energy control
employee procedures are implemented, as in lockout/tagout. An affected
employee and an authorized employee may be the same person.
Applied load The working loads to which mechanical equipment are subjected
when lifting and/or moving lines or other materials.
Area director The employee or officer regularly or temporarily in charge of an
Area Office of the Occupational Safety and Health Administration,
U.S. Department of Labor, or any other person or persons who
are authorized to act for such employee or officer.
3/13 Glossaries–1
Article As used in the Hazard Communication standard, an article is a

manufactured item other than a fluid or particle: (i) which is
formed to a specific shape or design during manufacture; (ii)
which has end use function(s) dependent in whole or in part upon
its shape or design during end use; and (iii) which under normal
conditions of use does not release more than very small
quantities, e.g., minute or trace amounts of a hazardous
chemical, and does not pose a physical hazard or health risk to
employees.
Asphyxiant A gas that is essentially non-toxic, but can cause
unconsciousness or death by lowering the concentration of
oxygen in the air or by totally replacing the oxygen in breathing
air.
Authorized One to whom the authority and responsibility to perform a
person specific assignment has been given by the employer.
Auto-ignition Temperature at which a material will self-ignite and sustain
temperature combustion without an outside ignition source.
Biomechanical The physical conditions of a workstation, tool setup, and work
stressor processes that place stress on the body.
Carcinogen A substance capable of causing cancer.
Carpal tunnel An anatomic feature in the wrist formed by the wrist bones and
the trans-carpal ligament through which the median nerve and
the nine digital flexor tendons pass.
Carpal tunnel A repetitive motion injury caused by the compression and
syndrome entrapment of the median nerve where it passes through the
wrist into the hand — in the carpal tunnel.
CAS number A CAS number is used to accurately identify chemicals through
the use of a unique Chemical Abstracts Service (CAS) registry
number.
Ceiling limit The maximum amount of a toxic substance allowed being in
workroom air at any time during the day.
Certified A certification awarded by the American Board of Industrial
Industrial Hygiene to individuals meeting established criteria.
Hygienist
Certified Safety A certification awarded by the Board of Certified Safety
Professional® Professionals to individuals meeting established criteria.
Chemical Inflammation of the lungs caused by accumulation of fluids due to
pneumonitis chemical irritation.
2–Glossaries 3/13
Chronic effect An adverse effect on the human body with symptoms that
develop slowly over a long period of time or which recur
frequently.
Chronic Long-term contact with a substance.
exposure
Combustible Able to catch on fire and burn.
Compliance A person trained and authorized by the Occupational Safety and
safety and Health Administration, U.S. Department of Labor to conduct
health officer inspections.
Confined space A space that: (1) Is large enough and so configured that an
employee can bodily enter and perform assigned work; (2) Has
limited or restricted means for entry or exit; and (3) Is not
designed for continuous employee occupancy.
Conjunctivitis Inflammation of the conjunctiva, the delicate membrane that lines
the eyelids and covers the eyeballs.
Cumulative (CTD) A disorder of the musculoskeletal and nervous system that
trauma disorder may be caused or aggravated by repetitive motions, forceful
exertions, vibration, mechanical compressions, sustained or
awkward postures, or by exposure to noise over extended
periods of time.
Dangerous An atmosphere that may expose employees to the risk of death,
atmosphere incapacitation, impairment of ability to self-rescue, injury, or acute
illness.
De minimus Violations of existing OSHA standards which have no direct or
immediate relationship to safety or health. Such violations of the
OSHA standards result in no penalty and no requirement for
abatement.
Dyspnea A sense of difficulty in breathing; shortness of breath.
Emergency A plan for a workplace, or parts thereof, describing what
action plan procedures the employer and employees must take to ensure
employee safety from fire or other emergencies.
Emergency An emergency spill or release refers to the after effects of an
release unintended release of hazardous, toxic, or explosive substances.
Employee An employee of an employer who is employed in a business of
his employer which affects commerce.
Employer A person engaged in a business affecting commerce who has
employees, but does not include the United States or any State
or political subdivision of a State.
3/13 Glossaries–3
Energy-isolating Any mechanical device that physically prevents the transmission

device or release of energy. These include, but are not limited to,
manually-operated electrical circuit breakers, disconnect
switches, line valves, and blocks.
Exit route A continuous and unobstructed path of exit travel from any point
within a workplace to a place of safety (including refuge areas).
An exit route consists of three parts: the exit access; the exit; and
the exit discharge. (An exit route includes all vertical and
horizontal areas along the route.)
Extremely Any one of over 300 hazardous chemicals on a list compiled by
hazardous EPA to provide a focus for State and local emergency planning
substance activities.
4–Glossaries 3/13
First aid For the purposes of 29 CFR 1904, “first aid” means:
(A) Using a non-prescription medication at nonprescription
strength (for medications available in both prescription and non-
prescription form, a recommendation by a physician or other
licensed health care professional to use a non-prescription
medication at prescription strength is considered medical
treatment for recordkeeping purposes);
(B) Administering tetanus immunizations (other immunizations,
such as Hepatitis B vaccine or rabies vaccine, are considered
medical treatment);
(C) Cleaning, flushing or soaking wounds on the surface of the
skin;
(D) Using wound coverings such as bandages, Band-Aids®,
gauze pads, etc.; or using butterfly bandages or Steri-Strips™
(other wound closing devices such as sutures, staples, etc., are
considered medical treatment);
(E) Using hot or cold therapy;
(F) Using any non-rigid means of support, such as elastic
bandages, wraps, non-rigid back belts, etc. (devices with rigid
stays or other systems designed to immobilize parts of the body
are considered medical treatment for recordkeeping purposes);
(G) Using temporary immobilization devices while transporting an
accident victim (e.g., splints, slings, neck collars, back boards,
etc.);
(H) Drilling of a fingernail or toenail to relieve pressure, or
draining fluid from a blister;
(I) Using eye patches;
(J) Removing foreign bodies from the eye using only irrigation or
a cotton swab;
(K) Removing splinters or foreign material from areas other than
the eye by irrigation, tweezers, cotton swabs or other simple
means;
(L) Using finger guards;
(M) Using massages (physical therapy or chiropractic treatment
are considered medical treatment for recordkeeping purposes);
(N) Drinking fluids for relief of heat stress.
Flammable As defined in OSHA’s 1910.106 standard, a flammable liquid
liquid means any liquid having a flashpoint at or below 199.4°F (93°C).
Flammable liquids are divided into four categories.
3/13 Glossaries–5
Flashpoint The minimum temperature at which a liquid gives off vapor within
a test vessel in sufficient concentration to form an ignitable
mixture with air near the surface of the liquid.
Floor hole An opening measuring less than 12 inches but more than one
inch in its least dimension, in any floor, platform, pavement, or
yard, through which materials but not persons may fall; such as a
belt hole, pipe opening, or slot opening.
Floor opening An opening measuring 12 inches or more in its least dimension,
in any floor, platform, pavement, or yard through which persons
may fall; such as a hatchway, stair or ladder opening, pit, or large
manhole. Floor openings occupied by elevators, dumb waiters,
conveyors, machinery, or containers are excluded from this
subpart.
General Duty Section 5.a.1 of the OSH Act which states “. . . that every
Clause employer covered under the Act furnish to his employees
employment and a place of employment which are free from
recognized hazards that are causing or are likely to cause death
or serious physical harm to his employees.”
Guard A barrier that prevents entry of the operator’s hands or fingers
into the point of operation.
Hazard not As defined in OSHA’s Hazard Communication standard, a
otherwise ″Hazard not otherwise classified (HNOC)″ means an adverse
classified physical or health effect identified through evaluation of scientific
(HNOC) evidence during the classification process that does not meet the
specified criteria for the physical and health hazard classes
addressed in §1910.1200. This does not extend coverage to
adverse physical and health effects for which there is a hazard
class addressed in §1910.1200, but the effect either falls below
the cut-off value/concentration limit of the hazard class or is
under a GHS hazard category that has not been adopted by
OSHA (e.g., acute toxicity Category 5).
HAZWOPER Hazardous Waste Operations and Emergency Response,
regulated under §1910.120.
Healthcare Physicians (PHCPs) or other licensed healthcare professionals
professional (LHCPs) with the appropriate license, registration or certificate
that allows them to provide a relevant opinion.
6–Glossaries 3/13
Health hazard A chemical which is classified as posing one of the following

hazardous effects: acute toxicity (any route of exposure); skin
corrosion or irritation; serious eye damage or eye irritation;
respiratory or skin sensitization; germ cell mutagenicity;
carcinogenicity; reproductive toxicity; specific target organ toxicity
(single or repeated exposure); or aspiration hazard. The criteria
for determining whether a chemical is classified as a health
hazard are detailed in Appendix A to §1910.1200—Health Hazard
Criteria.
Immediate The area, process, or machine which is creating the hazardous
release area spill.
Incidental An “incidental release” is a release of a hazardous substance
release which does not pose a significant safety or health hazard to
employees in the immediate vicinity or to the worker cleaning it
up, nor does it have the potential to become an emergency.
Inspection Any inspection of an employer’s factory, plant, establishment,
construction site, or other area, workplace or environment where
work is performed by an employee of an employer, and includes
any inspection conducted pursuant to a complaint filed under
1903.11(a) and (c), any re-inspection, follow-up inspection,
accident investigation or other inspection conducted under
suction 8(a) of the Act.
Ischemia Insufficient blood flow to an area, resulting in lack of oxygen and
nutrients for tissue to function properly.
Ladder A ladder is an appliance usually consisting of two side rails joined
at regular intervals by cross-pieces called steps, rungs, or cleats,
on which a person may step in ascending or descending.
Lockout/tagout Procedures using an energy isolating device which prevents
machinery from energizing and/or a tag that alerts employees
about the need for equipment to not be started.
Lost workdays The number of calendar days (consecutive or not) after, but not
including, the day of the injury or illness during which the
employee was unable to work, whether or not the employee was
scheduled to work.
Lower The minimum concentration of gas or vapor in air below which it
flammable limit is not possible to ignite the vapors.
Medical Includes treatment administered by physician or by registered
treatment professional personnel under the standing orders of a physician.
Medical treatment does not include first aid treatment even
though provided by a physician or registered professional
personnel.
3/13 Glossaries–7
Musculoskeletal (MSD) An illness of the soft tissues of the upper extremities,

disorder shoulders, neck, back, hips, legs or feet and toes cause primarily
by workplace risk factors, such as sustained or repeated
exertions or awkward postures and manipulations.
Nephrotoxin A substance that causes injury to the kidneys.
Neurotoxin A material that affects the nerve cells and may produce emotional
or behavioral abnormalities.
Occupational Maximum allowable concentrations of toxic substances in
exposure limits workroom air to protect workers who are exposed to toxic
substances over a working lifetime.
Odor threshold The lowest concentration of a substance’s vapor, in air, that can
be smelled.
Paresthesias An abnormal sensation of tingling and numbness.
Percent volatile The percentage of a chemical that will evaporate at ordinary
temperatures. A high volatile percentage may mean there is more
risk of explosion, or that dangerous fumes can be released.
Evaporation rates are a better measure of the danger than the
percent volatile measure.
Physical hazard A chemical that is classified as posing one of the following
hazardous effects: explosive; flammable (gases, aerosols, liquids,
or solids); oxidizer (liquid, solid or gas); self-reactive; pyrophoric
(liquid or solid); self-heating; organic peroxide; corrosive to metal;
gas under pressure; or in contact with water emits flammable
gas. See Appendix B to §1910.1200—Physical Hazard Criteria
Pinch point Any point other than the point of operation at which it is possible
for a part of the body to be caught between the moving parts of a
press or auxiliary equipment, or between moving and stationary
parts of a press or auxiliary equipment or between the material
and moving part or parts of the press or auxiliary equipment.
Point of That point at which cutting, shaping, boring, or forming is
operation accomplished upon the stock.
Pyrophoric gas A chemical in a gaseous state that will ignite spontaneously in air
at a temperature of 130 degrees F (54.4 degrees C) or below.
Raynaud’s A painful condition affecting the fingers or toes, caused by
syndrome compromised circulation.
8–Glossaries 3/13
Recordable Any occupational injury or illness which results in:

occupational • Death,
injuries or
• Days away from work,
illnesses
• Restricted work or transfer to another job,
• Medical treatment beyond first aid, or
• Loss of consciousness.
• An injury is also recordable if it involves a significant injury or
illness diagnosed by a physician or other licensed healthcare
professional, even if it does not result in any of the above
conditions.
Repetitive strain Injuries resulting to soft tissues from repeating the injurious
injury activity beyond the body’s ability to heal itself.
Reproductive Exposure that results in infertility, impotence, loss of sex drive
effects and birth defects.
Restricted work For the purposes of 29 CFR Part 1904, restricted work occurs
when, as the result of a work-related injury or illness:
• You keep the employee from performing one or more of the
routine functions of his or her job, or from working the full
workday that he or she would otherwise have been scheduled
to work; or
• A physician or other licensed health care professional
recommends that the employee not perform one or more of the
routine functions of his or her job, or not work the full workday
that he or she would otherwise have been scheduled to work.
Safety data Written or printed material concerning a hazardous chemical that
sheet (SDS) is prepared in accordance with specifications in the Hazard
Communication standard.
Short-term The airborne concentration of a material to which it is believed
exposure limits that workers can be exposed continuously for a short period of
time without suffering from harm.
Solvent Usually a liquid in which other substances are dissolved. The
most common solvent is water.
Standard A standard that requires conditions, or the adoption or use of one
or more practices, means, methods, operations, or processes,
reasonably necessary or appropriate to provide safe or healthful
employment and places of employment.
Standard As used in §1910.95, a standard threshold shift is a change in
threshold shift hearing threshold relative to the baseline audiogram of an
average of 10 dB or more at 2000, 3000, and 4,000 Hz in either
ear.
3/13 Glossaries–8A
Subpart Z Toxic and Hazardous Substances, the last subpart of 29 CFR

1910. Contains permissible exposure limits for air contaminants,
Tables Z-1, Z-2, and Z-3.
8B–Glossaries 3/13
Tagout device Any prominent warning device, such as tag and a means of
attachment, which can be securely fastened to an energy-
isolating device in accordance with an established procedure.
The tag indicates that the machine or equipment to which it is
attached is not to be operated until the tag-out device is removed
in accordance with the energy control procedure.
Teratogenic Capable of causing birth defects.
Threshold limit The airborne concentration of a material, representing conditions
value under which it is believed that nearly all workers may be
repeatedly exposed without adverse health effects.
Toxic substance Any substance that has the capacity to produce personal injury or
illness through ingestion, inhalation, or absorption through any
body surface.
Uncontrolled The accidental release of a hazardous substance from its
release container. If not contained, stopped, and removed, the release
would pose a hazard to employees in the immediate area or in
areas in the path of the release, or from its by-products or its
effects.
Upper explosive The maximum concentration of a flammable vapor above which
limit ignition will not occur even on contact with a source of ignition.
Upper The maximum concentration of gas or vapor in air above which it
flammable limit is not possible to ignite the vapors.
Volatile organic A fast evaporating substance used in coatings and in paints as
compound they evaporate very quickly.
WHMIS A Canadian workplace safety rule that requires the creation and
availability of material safety data sheets, warning labels on
hazardous materials, and employee education and training.
Z List The OSHA tables of permissible exposure limits (PELs) for air
contaminants, found in Subpart Z, Toxic and Hazardous
Substances, §1910.1000. Contains Tables Z-1, Z-2, and Z-3.
Glossaries–9
Glossary of Safety and Health Acronyms
AA Atomic Absorption
Absorption of electromagnetic radiation at discrete wavelengths by
atoms. The quantity of absorbed radiation is a measure of the
concentration or amount of that atom in the sample.
AAS Atomic Absorption Spectroscopy
Performed by stimulating a filament of a chosen element and using
the light emitted by the filament to detect the amount of that element
in a sample by measuring the absorption of the light.
AAOHN American Association of Occupational Health Nurses
ABIH American Board of Industrial Hygiene
The organization which conducts the testing for CIH and issues the
CIH credential.
ABSA American Biological Safety Association
A professional association for the exchange of biosafety information.
ACGIH American Conference of Governmental Industrial Hygienists
A professional association well known for establishing and publishing
the TLVs, for publishing the Industrial Ventilation Manual, and as one
of the sponsors of the ABIH and AIHCE.
ACM Asbestos Containing Material
ACS American Chemical Society
ADA Americans with Disabilities Act
ADAAG Americans with Disabilities Act Accessibility Guidelines
AE Atomic Emission
The emission of electromagnetic radiation at discrete wavelengths by
exited atoms. Quantity of emitted light is a measure of the
concentration or amount of that atom present in a sample.
AES Atomic Emission Spectrophotometry
Analysis by detection and quantification of the characteristic
electromagnetic emissions from atoms in a sample.
AFL-CIO American Federation of Labor and Congress of Industrial
Organizations
AGA American Gas Association
10–Glossaries
AHERA Asbestos Hazard Emergency Response Act of 1986 (Title II of

TSCA)
U.S. Federal legislation requiring all schools to determine the location
and condition of asbestos containing material, and setting up
procedures for issuing credentials to those who disturb asbestos for
testing or removal.
AIHA American Industrial Hygiene Association
The broad professional association for industrial hygienists in the U.S.
and Canada, with local sections also in parts of Europe. This
association is the largest professional industrial hygiene/occupational
hygiene association in the world.
AIHCE American Industrial Hygiene Conference and Exposition
Annual, week long, professional conference jointly sponsored by the
AIHA and the ACGIH in the spring.
ALARA As Low As Reasonably Achievable
A philosophy applied to the control of exposure to ionizing radiation.
ALCM Associate in Loss Control Management
A credential issued by the Insurance Institute of America.
ANSI American National Standards Institute
Oversees organizations who publish consensus standards on a wide
variety of subjects, including safety equipment, procedures, etc.
APF Assigned Protection Factor
Used in the context of respiratory protection.
API American Petroleum Institute
APR Air Purifying Respirator
AQTX Aquatic Toxicity
ASA Accredited Safety Auditor
ASAE American Society of Agricultural Engineers
ASHRAE American Society of Heating, Refrigerating and Air Conditioning
Engineers
A group that publishes a well regarded multi-volume handbook which
includes ventilation guidance, and standards on IAQ and other
ventilation related issues.
ASME American Society of Mechanical Engineers
ASOII Annual Survey of Occupational Injuries and Illnesses
Glossaries–11
ASP Associate Safety Professional

Designation given to someone who has successfully completed the
first half of the examination processes for CSP®.
ASSE American Society of Safety Engineers
The national professional society for Safety Engineers in the U.S.
AST Aboveground Storage Tank
ASTM American Society for Testing and Materials
ATSDR Agency for Toxic Substances and Disease Registry
An agency of the Public Health Service in the U.S. Department of
Health and Human Services.
AWS American Welding Society
AWT Advanced Wastewater Treatment
BACT Best Available Control Technology
A term used in U.S. environmental control regulations.
BAT Best Available Technology
BATEA Best Available Technology Economically Achievable
Terminology for sewage cleanup technology to be applied under
Canadian Municipal-Industrial Strategy for Abatement, for cleanup of
Great Lakes water sources.
BBP Bloodborne Pathogens
Pathogenic microorganisms that are present in human blood and can
cause disease in humans. These pathogens include, but are not
limited to, hepatitis B virus (HBV) and human immunodeficiency virus
(HIV).
BBS Behavior-Based Safety
A safety-oriented philosophy that focuses on the observable actions of
employees, as well as the objective environmental or cultural factors
that influence behavior
BCSP Board of Certified Safety Professionals
The certifying organization that issues the ASP, CSP, and COHST
credentials following review of experience and successful completion
of written tests.
BD 1,2-Butadiene
BEI Biological Exposure Indices
BLEVE Boiling Liquid Expanding Vapor Explosion
12–Glossaries
BLS Bureau of Labor Statistics

An agency of the U.S. government which gathers statistical
information on labor issues, employment data, and accident rates.
BMI Body Mass Index
BOD Basic Oxygen Demand; Biological Oxygen Demand
The oxygen demand if a water sample is biologically oxidized.
BOHS British Occupational Hygiene Society
The national professional society of Occupational Hygienists in the
United Kingdom.
BOMA Building Owners and Managers Association International
BPT Best Practicable Control Technology
BSC Biological Safety Cabinet
BTU British Thermal Unit
A traditional unit of measure for heat.
CAA Clean Air Act
CAP College of American Pathologists
CAS Chemical Abstract Service
Publisher of Chemical Abstracts and other publications and services.
CBC Complete Blood Count
CCC Compromised Container Caps
Cracked or otherwise damaged screw-on caps for chemical
containers.
CCPS Center for Chemical Process Safety
An organization established by the American Institute of Chemical
Engineers (AIChE) to focus on engineering practices to help prevent
and mitigate catastrophic hazardous chemical accidents.
CDC Centers for Disease Control
The organization within the US National Institutes of Health, Public
Health Service that specializes in recognition, evaluation and control of
communicable diseases. NIOSH is part of CDC.
CDL Commercial Driver’s License
CEEL Community Emergency Exposure Level
A sort of PEL for a whole community; intended as a guideline for when
evacuations are necessary in case of accidental releases.
Glossaries–13
CEPP Chemical Emergency Preparedness Program

CERCLA Comprehensive Environmental Response, Compensation, and
Liability Act (Superfund)
U.S. Federal legislation establishing a huge EPA project to clean up
hazardous material dumps. It requires generators to be responsible for
how waste is ultimately disposed.
CFC Chlorofluorocarbons
Any of several compounds composed of carbon, fluorine, chlorine, and
hydrogen used primarily as refrigerants CFCs are thought to be
ozone-depleting chemicals.
CFM Cubic Feet per Minute
A unit of measure for things such as airflow that is used in evaluating
ventilation systems.
CFR Code of Federal Regulations
The compilation of all regulations issued by U.S. Federal Government
agencies.
CGA Compressed Gas Association
CGI Combustible Gas Indicator
CHMM Certified Hazardous Materials Manager
A credential awarded by the Institute of Hazardous Materials
Management.
CHO Chemical Hygiene Officer
The Administrator of a Chemical Hygiene Plan under OSHA
regulations.
CHP Chemical Hygiene Plan
Required by OSHA’s laboratory standard, a statement of laboratory
work practices written by each employer.
CIH Certified Industrial Hygienist
A certification awarded by the American Board of Industrial Hygiene to
individuals meeting stated criteria.
CHP Chemical Hygiene Plan
CMA Chemical Manufacturers Association
CMAA Crane Manufacturers Association of America, Inc.
CNS Central Nervous System
14–Glossaries
COD Chemical Oxygen Demand

Oxygen demand if a substance is chemically oxidized.
CPL Compliance Directive
A published document that offers deeper insight on an OSHA
standard.
CPR Cardiopulmonary Resuscitation
CPSC Consumer Product Safety Commission
A U.S. Federal agency geared to protect the public from unsafe
products.
CSA Canadian Standards Association
The national consensus standards association for Canada. It is
roughly equivalent to ANSI.
CSHO Compliance Safety and Health Officer
An officer of the Occupational Safety and Health Administration
(OSHA).
CSP® Certified Safety Professional®
A certification awarded by the Board of Certified Safety Professionals
to individuals meeting stated criteria.
CTD Cumulative Trauma Disorder
A disorder of the musculoskeletal and nervous systems that may be
caused or aggravated by repetitive motions, forceful exertions,
vibration, mechanical compressions, sustained or awkward postures,
or by exposure to noise over extended periods of time.
CTS Carpal Tunnel Syndrome
The compression and entrapment of the median nerve where it
passes through the wrist into the hand via the carpal tunnel.
CWA Clean Water Act
DAFWII Days Away from Work Injury Illness
Refers to an incident rate calculated using cases that involve days
away from work per 100 full-time equivalent employees.
DART Days Away Restricted and Job Transfer Rate of Injuries and
Illnesses
Refers to an incident rate calculated using cases that involve days
away from work, restricted work activity, and transfers to another job.
dB Decibels
A unit of measure of sound intensity.
Glossaries–15
dBA Decibels on the A scale

DEP Diethyl Phthalate
DFM Dust, Fume, and Mist
This refers to a respirator filter cartridge suitable for use against dusts,
fumes, or mists, and is used in the NIOSH regulation on Respirator
Certification.
DHHS Department of Health and Human Services
A federal agency which contains the CDC and NIOSH.
DHMM Director of Hazardous Materials Management
The person in charge of handling hazardous materials.
DM Dust and Mist
This refers to a respirator filter cartridge suitable for use against dusts
and mists, and is used in the NIOSH regulation on Respirator
Certification.
DOE Department of Energy
DOL Department of Labor
DOP Dioctyl Phthalate
The traditional test aerosol used for determining HEPA filter efficiency
was an aerosolized form of warm DOP, selected because, when
generated in the specified manner, the aerosol had a very narrow size
distribution.
DOT Department of Transportation
EAP Emergency Action Plan
A plan for a workplace, or parts thereof, describing what procedures
the employer and employees must take to ensure employee safety
from fire or other emergencies.
EHS Extremely Hazardous Substance; also Environmental Health and
Safety
EMR Electro-Magnetic Radiation
Radiation caused by electromagnetism.
EMS Emergency Medical Service
EPA Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
Title III of SARA that requires facilities that store reportable quantities
of hazardous materials to report to the LEPC.
16–Glossaries
ERG Emergency Response Guide

A document that provides guidance on emergency response in a
transportation incident involving chemicals.
ERP Emergency Response Plan
A planned response effort by employees from outside the immediate
release area or by other designated responders to an occurrence that
results, or is likely to result, in an uncontrolled release of a hazardous
substance.
ERT Emergency Response Team
The team responsible for responding to an emergency.
ESLI End-of-Service-Life Indicator
f/cc Fibers per cubic centimeter of air
FEMA Federal Emergency Management Agency
FID Flame Ionization Detector
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FIRM Field Inspection Reference Manual
An OSHA publication, now replaced by the Field Operations Manual,
that provided direction and guidance to Compliance Officers
concerning all phases of compliance inspections.
FOIA Freedom of Information Act
FOM Field Operations Manual
An OSHA publication, which replaced the Field Inspection Reference
Manual, providing direction and guidance to Compliance Officers
concerning all phases of compliance inspections.
FOPS Falling Object Protective Structure
FR Federal Register
A federal publication published each business day recounting all
federal agency activity.
GC Gas Chromography
GHS Globally Harmonized System of Classification and Labeling of
Chemicals
A system for standardizing and harmonizing the classification and
labeling of chemicals.
GSA General Services Administration
HAVS Hand-Arm Vibration Syndrome
Glossaries–17
HazCom Hazard Communication

HAZMAT Hazardous Materials
HAZOP Hazard and Operability (study)
A structured means of evaluating a complex process to determine
problems associated with its operability or safety.
HAZWOPER Hazardous Waste Operations and Emergency Response
HBV Hepatitis B Virus
HCP Healthcare Professional
HCS Hazard Communication Standard
A Federal standard requiring employers to communicate potential
hazards to employees.
HCV Hepatitis C Virus
HEPA High Efficiency Particulate Air (filter)
A filter that is at least 99.97% efficient in the filtration of air borne
particles that are at least 0.3 microns in diameter.
HIV Human Immunodeficiency Virus
HMIS Hazardous Materials Identification System
HMTA Hazardous Materials Transportation Act
HPD Hearing Protection Device
IAQ Indoor Air Quality
The level of air quality inside of a building. Refers to situations where
building occupants experience health and discomfort effects that
appear to be linked to time spent in a building.
IARC International Agency for Research on Cancer
ICS Incident Command System
Procedure for emergency management used by fire departments and
other emergency response teams.
IDLH Immediately Dangerous to Life and Health
IIPP Injury and Illness Prevention Program (also referred to as I2P2).
I2P2 A term OSHA is using to describe its Injury and Illness
Prevention Program rulemaking. Also referred to as IIPP.
IOHS International Occupational Hygiene Society
IR Infrared
ISEA Industrial Safety Equipment Association
18–Glossaries
ISO International Organization for Standardization

LC-50 Low Concentrate - 50 percent
The concentration in air which is lethal to 50 percent of the test
animals in a study.
LD-50 Lethal Dose - 50 percent
The experimental dose that is lethal to 50 percent of the test animals
in a study.
LEL Lower Explosive Limit
The minimum percent by volume of a gas or vapor, that when mixed
with air, will form a flammable mixture.
LEPC Local Emergency Planning Committee
LFL Lower Flammable Limit
LOAEL Lowest Observed Adverse Effect Level
The lowest dose which produces an observable adverse effect.
LOI Letter of Interpretation
OSHA’s interpretation of current requirements as they relate to a
specific set of circumstances.
LOTO Lock Out/Tag Out
Procedures using an energy isolating device or a tag that alerts
employees about the need for equipment to not be started.
LPG Liquid Propane Gas
LUST Leaking Underground Storage Tank
MC Methylene Chloride
MDA 4,4’ Methylenedianiline
MRI Magnetic Resonance Imagery
MSD Musculoskeletal Disorders
MSHA Mine Safety and Health Administration
MWF Metalworking Fluids
Fluids that are involved in metalworking procedures, including straight
oil, soluble oil, semisynthetic oil, and synthetic oil.
NADC National Association of Demolition Contractors
NAICS North American Industry Classification Standard
NAS National Academy of Sciences
3/13 Glossaries–19
NATE National Association of Tower Erectors

NEMA National Electrical Manufacturer’s Association
NEP National Emphasis Program
An enforcement program whereby OSHA focuses on a specific issue
of national importance, e.g., combustible dust.
NESHAP National Emissions Standards for Hazardous Air Pollutants
NFPA National Fire Protection Association
NHCA National Hearing Conservation Association
NHTSA National Highway Traffic Safety Administration
NIEHS National Institute of Environmental Health Sciences
NIH National Institutes of Health
NIHL Noise Induced Hearing Loss
NIOSH National Institute of Occupational Safety and Health
NIST National Institute of Standards and Technology
NOAEL No Observed Adverse Effect Level
NPR Notice of Proposed Rulemaking
A step in the formal process of issuing regulations by U.S. agencies.
NRC Nuclear Regulatory Commission
The U.S. Federal Regulatory Agency which deals with radiation and
radioactive materials.
NRR Noise Reduction Rating
A rating given as a laboratory based indicator of the relative
effectiveness of hearing protectors.
NRTL Nationally Recognized Testing Laboratory
NSC National Safety Council (Congress)
NTP National Toxicology Program
A program of the U.S. Government that tests chemical agents for long
terms toxic effects.
OMB Office of Management and Budget
ORM Other Regulated Material
Terms used in HAZMAT shipping.
OSH Act Occupational Safety and Health Act of 1970
OSHA Occupational Safety and Health Administration
20–Glossaries 3/13
OSHRC Occupational Safety and Health Review Commission

The branch of the federal government under the Department of Labor
that oversees occupational safety and health litigation decisions.
OVA Organic Vapor Analyzer
PAPR Powered Air-Purified Respirator
PCB Polychlorinated Biphenyl
PDS Personnel Decontamination Station
PEL Permissible Exposure Limits
The maximum occupational exposure permitted under the OSHA
regulations.
PLHCP Physician of Other Licensed Healthcare Provider
PMA Petition for Modification of the Abatement
PPB Parts Per Billion
Parts of a contaminant per billion parts of air or fluid.
PPE Personal Protective Equipment
Equipment used to protect employees that they wear upon their
person. Includes gloves, hard hats, respirators, shoes, etc.
PPM Parts Per Million
Parts of a contaminant per million parts of air or fluid.
PSM Process Safety Management
OSHA’s 1910.119 standard containing requirements for managing
highly hazardous chemicals.
PVC Polyvinyl Chloride
RCRA Resource Conservation and Recovery Act
REL Recommended Exposure Limit
A recommended exposure level for a particular agent or category of
agents.
RMA Rubber Manufacturer’s Association
RMI Repetitive Motion Injuries
Injuries caused by continued repetitive motions.
RMP Risk Management Plan
A written program that is required by the Clean Air Act. It is designed
to prevent accidental releases into the environment.
3/13 Glossaries–21
ROPS Rollover Protective Structure

A structure designed to protect an occupant of a vehicle if it should roll
over, such as a roll bar or a roll cage on a forklift.
RPM Revolution Per Minute
RSI Repetitive Strain Injury
Injury caused by repeated strains.
RTECS The Registry of Toxic Effects of Chemical Substances
RTK Right To Know
The right of employees to know about the nature and hazards of
agents used in the work place, and/or to the right of communities and
their members to know about materials used and wastes generated by
workplaces situated within or adjacent to the community.
SAR Supplied Air Respirator
A respirator that has a direct supply of breathable air.
SARA Superfund Amendments and Reauthorization Act
A federal fund set aside to clean up existing hazardous waste sites.
SCBA Self-Contained Breathing Apparatus
An atmosphere supplying respirator for which the breathing air source
is designed to be carried by the user.
SDS Safety Data Sheet
Written or printed material concerning a hazardous chemical. It is
prepared by the manufacturer in accordance with §1910.1200.
SERC State Emergency Response Committee
SIC Standard Industrial Classification
SOP Standard Operating Procedure
STEL Short Term Exposure Limit
TB Tuberculosis
An infectious disease caused by the tubercle bacillus and
characterized by the formation of tubercles in various tissues of the
body.
TLV Threshold Limit Value
An exposure limit recommended by the ACGIH. It is believed that, at
this level, nearly all workers can be exposed day after day for a
working lifetime without ill effect.
TLV-STEL Threshold Limit Value — Short-term Exposure Limit
22–Glossaries 3/13
TSCA Toxic Substance Control Act

TWA Time-Weighted Average
UBC Uniform Building Code
UEL Upper Explosive Limit
UFC Uniform Fire Code
UFL Upper Flammable Limit
UL Underwriters Laboratories
USC United States Code
USCG U. S. Coast Guard
UST Underground Storage Tank
UV Ultraviolet
VDT Video Display Terminal
VOC Volatile Organic Compound
VPP Voluntary Protection Program
An OSHA program that promotes excellence in workplace safety and
health programs in exchange for limitations on scheduled inspections
by OSHA.
WHMIS Workplace Hazardous Materials Information System
The Canadian workplace safety rule, WHMIS requires the creation and
availability of material safety data sheets, warning labels on hazardous
materials, and employee education and training.
Glossaries–23
Reserved
24–Glossaries
Agency Contacts
OSHA Local Area Offices

The following is a list of addresses and telephone numbers of OSHA Local Area Offices.
These offices are sources of information, publications, and assistance in understanding the
requirements of the standards. These addresses are current as of August 4, 2014.
Alabama Phoenix Area Office
http://labor.alabama.gov/ Arizona Division of Occupational Safety
Birmingham Area Office and Health (ADOSH)
Medical Forum Building 800 W. Washington St., 2nd floor
950 22nd Street North, Room 1050 Phoenix, AZ 85007
Birmingham, AL 35203 (602) 542-5795
(205) 731-1534 Fax: (602) 542-1614
Fax: (205) 731-0504 Arkansas
Mobile Area Office www.labor.ar.gov/Pages/default.aspx
1141 Montlimar Drive, Suite 1006 Little Rock Area Office
Mobile, AL 36609 10810 Executive Center Dr.
(334) 441-6131 Danville Building #2, Suite 206
Fax: (334) 441-6396 Little Rock, AR 72211
(501) 224-1841
Alaska
Fax: (501) 224-4431
www.labor.state.ak.us/
Anchorage Area Office California
Scott Ketcham, Area Director www.dir.ca.gov/occupational_safety.html
U.S. Department of Labor - OSHA California Department of Industrial
222 W. 7th Avenue, Box 22 Relations
Anchorage, AK 99513 Office of the Director
(907) 271-5152 1515 Clay St., 17th Floor
Fax: (907) 271-4238 Oakland, CA 94612
(510) 622-3965
Arizona
Oakland Area Office
www.ica.state.az.us/ADOSH/ U.S. Department of Labor - OSHA
ADOSH_main.aspx Ronald Dellums Federal Building
Industrial Commission of Arizona 1301 Clay St., Suite 1080 N
800 West Washington Street, 2nd Floor Oakland, CA 94612-5217
Phoenix, AZ 85007 (510) 637-3800
(602) 542-5795 Fax: (510) 637-3846
Fax: (602) 542-1614
San Diego Area Office
Tucson office U.S. Department of Labor - OSHA
2675 E. Broadway Blvd. #239 550 West C St., Suite 970
Tucson, AZ 85716 San Diego, CA 92101-3540
(520) 628-5478 (619) 557-5030
Fax: (520) 322-8008 Fax: (619) 557-6001
9/14 Agency Contacts–1

Colorado Florida
www.colorado.gov/cs/Satellite/CDLE- www.myflorida.com
LaborLaws/CDLE/1240336908932 Fort Lauderdale Area Office
Denver Area Office 1000 South Pine Island Road, Suite 100
1391 Speer Boulevard, Suite 210 Fort Lauderdale, FL 33324
Denver, CO 80204-2552 (954) 424-0242
(303) 844-5285 Fax: (954) 424-3073
Fax: (303) 844-6676 Jacksonville Area Office
Englewood Area Office Ribault Building, Suite 227
7935 East Prentice Avenue, Suite 209 1851 Executive Center Drive
Englewood, CO 80111-2714 Jacksonville, FL 32207
(303) 843-4500 (904) 232-2895
Fax: (303) 843-4515 Fax: (904) 232-1294
Connecticut Tampa Area Office
www.ctdol.state.ct.us/ 5807 Breckenridge Parkway, Suite A
Bridgeport Area Office Tampa, FL 33610-4249
Clark Building (813) 626-1177
1057 Broad Street, 4th Floor Fax: (813) 626-7015
Bridgeport, CT 06604 Georgia
(203) 579-5581 http://www.dol.state.ga.us/
Fax: (203) 579-5516 Atlanta East Area Office
Hartford Area Office LaVista Perimeter Office Park
William R. Cotter Federal Building 2183 North Lake Parkway, Building 7
135 High St., Room 361 Suite 110
Hartford, CT 06103 Tucker, GA 30084-4154
(860) 240-3152 (770) 493-6644
Fax: (860) 240-3155 Fax: (770) 493-7725
Delaware Atlanta West Area Office
www.delawareworks.com/ 1995 North Park Place S.E., Suite 525
Wilmington Area Office Atlanta, GA 30339
Mellon Bank Building, Suite 900 (678) 903-7301
919 Market Street Fax: (770) 984-8855
Wilmington, DE 19801-3319 Savannah Area Office
(302) 573-6518 450 Mall Boulevard, Suite J
Fax: (302) 573-6532 Savannah, GA 31406
District of Columbia (912) 652-4393
Fax: (912) 652-4329
Baltimore/Washington, D.C. Area Office
OSHA Area Office
U.S. Department of Labor-OSHA
1099 Winterson Road, Suite 140
Linthicum, MD 21090
(410) 865-2055/2056
Fax: (410) 865-2068
2–Agency Contacts 9/14

Hawaii Indiana
http://labor.hawaii.gov/ www.state.in.us/dol/
Honolulu Area Office Indianapolis Area Office
U.S. Dept. of Labor – OSHA 46 East Ohio Street, Room 453
Prince Jonah Kuhio Kalanianaole Federal Indianapolis, IN 46204
Building (317) 226-7290
Fax: (317) 226-7292
300 Ala Mona Blvd., Room 5-146
Honolulu, HI 96850 Iowa
(808) 541-2680 www.iowaworkforce.org/
Fax: (808) 541-3456 U.S. Department of Labor - OSHA
210 Walnut Street, Room 815
Idaho
Des Moines, IA 50309-2015
http://labor.idaho.gov/ (515) 284-4794
Boise Area Office Fax: (515) 284-4058
1150 North Curtis Road, Suite 201
Boise, ID 83706 Kansas
(208) 321-2960 www.kdhe.state.ks.us/
Fax: (208) 321-2966 Wichita Area Office
100 N. Broadway, Suite 470
Illinois Wichita, KS 67202
www.illinois.gov/idol/Pages/default.aspx (316) 269-6644
Calumet City Area Office (800) 362-2896 (Kansas residents only)
1600 167th Street, Suite 9 Fax: (316) 269-6185
Calumet City, IL 60409 Kentucky
(708) 891-3800
www.labor.ky.gov/Pages/LaborHome.aspx
Fax: (708) 862-9659
Nashville Area Office
Chicago North Area Office 51 Century Boulevard Suite 340
701 Lee Street, Suite 950 Nashville, TN 37214
Des Plaines, IL 60016 (615) 232-3803
(847) 803-4800 Fax: (615) 232-3827
Fax: (847) 390-8220 Louisiana
Fairview Heights District Office www.ldol.state.la.us/
11 Executive Drive, Suite 11 Baton Rouge Area Office
Fairview Heights, IL 62208 9100 Bluebonnet Center Boulevard, Suite
(618) 632-8612 201
Fax: (618) 632-5712 Baton Rouge, LA 70809
North Aurora Area Office (225) 298-5458
365 Smoke Tree Plaza Fax: (225) 298-5457
North Aurora, IL 60542 Maine
(630) 896-8700 www.state.me.us/labor/
Fax: (630) 892-2160 Augusta Area Office
Peoria Area Office E.S. Muskie Federal Building
1320 West Commerce Drive 40 Western Avenue, Room G-26
Peoria, IL 61615-1462 Augusta, ME 04330
(309) 589-7033 (207) 626-9160
Fax: (309) 589-7326 Fax: (207) 622-8213

Bangor District Office Minnesota

382 Harlow Street www.dli.mn.gov/Main.asp
Bangor, ME 04401 There are no area offices in Minnesota.
(207) 941-8177 Contact the area office in Eau Claire, WI
Fax: (207) 941-8179 at:
Maryland 1310 W. Clairemont Avenue
Eau Claire, WI 54701
www.dllr.state.md.us
(715) 832-9019
Baltimore/Washington, DC Area Office
Fax: (715) 832-1147
OSHA Area Office
U.S. Department of Labor-OSHA Mississippi
1099 Winterson Road, Suite 140 www.ms.gov/home/
Linthicum, MD 21090 Jackson Area Office
(410) 865-2055/2056 Dr. A.H. McCoy Federal Bldg.
Fax: (410) 865-2068 100 West Capitol St., Suite 749
Massachusetts Jackson, MS 39269-1620
(601) 965-4606
http://www.mass.gov/lwd/
Fax: (601) 965-4610
North Boston Area Office
Shattuck Office Center Missouri
138 River Road, Suite 102 http://labor.mo.gov/
Andover, MA 01810 Kansas City Area Office
(978) 837-4460 2300 Main Street, Suite 168
Fax: (978) 837-4455 Kansas City, MO 64108
South Boston Area Office (816) 483-9531
639 Granite Street, 4th Floor (800) 892-2674 (Missouri residents only)
Braintree, MA 02184 Fax: (816) 483-9724
(617) 565-6924 St. Louis Area Office
Fax: (617) 565-6923 1222 Spruce Street, Room 9.104
Springfield Area Office St. Louis, MO 63103
1441 Main Street, Room 550 (314) 425-4249
Springfield, MA 01103-1493 Voice Mail: (314) 425-4255
(413) 785-0123 (800) 392-7743 (Missouri residents only)
Fax: (413) 785-0136 Fax: (314) 425-4289
Michigan Montana
www.michigan.gov/lara/0,4601,7-154- http://dli.mt.gov/
61256_11407---,00.html Billings Area Office
Lansing Area Office Jeff Funke, Area Director
U.S. Department of Labor 2900 4th Avenue North, Suite 303
Occupational Safety and Health Billings, MT 59101
Administration (406) 247-7494
315 West Allegan St., Room 207 Fax: (406) 247-7499
Lansing, MI 48933
(517) 487-4996
Fax: (517) 487-4997

Nebraska Hasbrouck Heights Area Office

www.dol.nebraska.gov 500 Route 17 South, 2nd Floor
Omaha Area Office Hasbrouck Heights, NJ 07604
444 Regency Parkway Drive, Suite 303 (201) 288-1700
Omaha, NE 68114 Fax: (201) 288-7315
(402) 553-0171
(800) 642-8963 (Nebraska residents only) Marlton Area Office
Fax: (402) 551-1288 Marlton Executive Park, Building 2
701 Route 73 South, Suite 120
Nevada Marlton, NJ 08053
http://dirweb.state.nv.us/ (856) 596-5200
Fax: (856) 596-5201
Nevada OSHA
1301 North Green Valley Parkway, Suite Parsippany Area Office
200 299 Cherry Hill Road, Suite 103
Henderson, NV 89074 Parsippany, NJ 07054
(702) 486-9020 (973) 263-1003
Fax: (702) 990-0365 Fax: (973) 299-7161
Reno Office New Mexico
4600 Kietzke Lane, Suite F-153 www.dws.state.nm.us/
Reno, NV 89502 There are no area offices in New Mexico.
(775) 824-4600 Contact the area office in Lubbock, TX
Fax: (775) 688-1378 at:
Las Vegas Area Office Lubbock Area Office
U. S. Department of Labor - OSHA 1205 Texas Avenue, Room 806
Alan Bible Federal Building Lubbock, TX 79401
600 Las Vegas Blvd. South, Suite 750 (806) 472-7681
Las Vegas, NV 89101 Fax: (806) 472-7686
(702) 388-6150 New York
Fax: (702) 388-6160 www.labor.ny.gov/home/
New Hampshire Albany Area Office
www.nh.gov/labor/ 401 New Karner Road, Suite 300
Concord Area Office Albany, NY 12205-3809
J.C. Cleveland Federal Building (518) 464-4338
53 Pleasant Street, Suite 3901 Fax: (518) 464-4337
Concord, NH 03301 Buffalo Area Office
(603) 225-1629 U.S. Dept. of Labor/OSHA
Fax: (603) 225-1580 130 South Elmwood Avenue, Suite 500
New Jersey Buffalo, NY 14202-2465
(716) 551-3053
http://lwd.dol.state.nj.us/labor/lsse/
Fax: (716) 551-3126
safetyhealth_index.html
Avenel Area Office Long Island Area Office
1030 St. Georges Avenue 1400 Old Country Road
Plaza 35, Suite 205 Suite 208
Avenel, NJ 07001 Westbury, NY 11590
(732) 750-3270 (516) 334-3344
Fax: (732) 750-4737 Fax: (516) 334-3326

Manhattan Area Office Ohio

201 Varick Street, Room 908 www.ohiobwc.com/employer/programs/
New York, NY 10014 safety/SandHOSHAOnsiteDetails.asp
(212) 620-3200 Cincinnati Area Office
Fax: (212) 620-4121 36 Triangle Park Drive
Queens District Office of the Manhattan Cincinnati, OH 45246
Area Office (513) 841-4132
45-17 Marathon Parkway Fax: (513) 841-4114
Little Neck, NY 11362 Cleveland Area Office
(718) 279-9060 Essex Place
Fax: (718) 279-9057 6393 Oak Tree Blvd., Suite 203
Syracuse Area Office Cleveland, OH 44131-6964
3300 Vickery Road (216) 447-4194
North Syracuse, NY 13212 Fax: (216) 520-1624
(315) 451-0808 Columbus Area Office
Fax: (315) 451-1351 200 North High Street, Room 620
Tarrytown Area Office Columbus, OH 43215
660 White Plains Road, 4th Floor (614) 469-5582
Tarrytown, NY 10591-5107 Fax: (614) 469-6791
(914) 524-7510 Toledo Area Office
Fax: (914) 524-7515 420 Madison Avenue, Suite 600
North Carolina Toledo, OH 43604
(419) 259-7542
www.nclabor.com/osha/osh.htm
Fax: (419) 259-6355
Raleigh Area Office
4407 Bland Road Oklahoma
Somerset Park, Suite 210 www.ok.gov/odol/
Raleigh, NC 27609 OSHA_Safety_Pays_Consultation_/
(919) 790-8096 index.html
Fax: (919) 790-8224 Oklahoma City Area Office
North Dakota 55 North Robinson, Suite 315
Oklahoma City, OK 73102-9237
www.nd.gov/labor/index.html
(405) 278-9560
Bismarck Area Office
Fax: (405) 278-9572
Eric Brooks, Area Director
U.S. Department of Labor Oregon
Occupational Safety and Health www.cbs.state.or.us/external/osha/
Administration Portland Area Office
521 East Main Avenue, Suite 200 911 NE 11th Ave., Suite 649
Bismarck, ND 58501 Portland, OR 97232
(701) 250-4521 (503) 231-2017
Fax: (701) 250-4520 Fax: (503) 231-2329

Pennsylvania Rhode Island

www.dli.state.pa.us/landi/site/default.asp www.dlt.ri.gov/occusafe/
Allentown Area Office Providence Area Office
Stabler Corporate Center Federal Office Building
3477 Corporate Parkway 380 Westminster Mall, Room 543
Suite 120 Providence, RI 02903
Center Valley, PA 18034 (401) 528-4669
(267) 429-7542
Fax: (267) 429-7567 Fax: (401) 528-4663
Erie Area Office South Carolina

1128 State Street, Suite 200 www.llr.state.sc.us/
Erie, PA 16501 Columbia Area Office
(814) 874-5150 Strom Thurmond Federal Building
Fax: (814) 874-5151 1835 Assembly Street, Room 1472
Harrisburg Area Office Columbia, SC 29201-2453
43 Kline Plaza (803) 765-5904
Harrisburg, PA 17104-1529 Fax: (803) 765-5591
(717) 782-3902 South Dakota
Fax: (717) 782-3746
http://dlr.sd.gov/
Philadelphia Area Office There are no area offices in South Dakota.
U.S. Custom House, Room 242 Contact the regional office in Bismarck,
Second & Chestnut Street ND at:
Philadelphia, PA 19106-2902 Bismarck Area Office
(215) 597-4955 Eric Brooks, Area Director
Fax: (215) 597-1956 U.S. Department of Labor
Pittsburgh Area Office Occupational Safety and Health
U.S. Department of Labor-OSHA Administration
William Moorhead Federal Building, Room 521 East Main Avenue, Suite 200
905 Bismarck, ND 58501
1000 Liberty Avenue (701) 250-4521
Pittsburgh, PA 15222 Fax: (701) 250-4520
(412) 395-4903 Tennessee
Fax: (412) 395-6380 www.tn.gov/labor-wfd/tosha.shtml
Wilkes-Barre Area Office Nashville Area Office
The Stegmaier Building, Suite 410 51 Century Boulevard Suite 340
7 North Wilkes-Barre Boulevard Nashville, TN 37214
Wilkes-Barre, PA 18702-5241 (615) 232-3803
(570) 826-6538 Fax: (615) 232-3827
Fax: (570) 821-4170 Texas
Puerto Rico www.twc.state.tx.us/
Puerto Rico Area Office Austin Area Office
Triple S Building La Costa Green Bldg.
1510 FD Roosevelt Avenue, Suite 5B 1033 La Posada Drive, Suite 375
Guaynabo, Puerto Rico 00968 Austin, TX 78752-3832
(787) 277-1560 (512) 374-0271
Fax: (787) 277-1567 Fax: (512) 374-0086

Corpus Christi Area Office Utah

Wilson Plaza http://laborcommission.utah.gov/ UOSH/
606 North Carancahua, Suite 700 Index.html
Corpus Christi, TX 78476 There are no area offices in Utah. Contact
(361) 888-3420 the regional office in Denver, CO at:
Fax: (361) 888-3424 Herb Gibson, Area Director
Dallas Area Office U.S. Department of Labor
1100 East Campbell Road, Suite 250 Occupational Safety and Health
Richardson, TX 75081 Administration
(972) 952-1330 1391 Speer Boulevard, Suite 210
El Paso Area Office Denver, CO 80204-2552
U.S. Dept. of Labor - OSHA (303) 844-5285, Ext. 106
4849 North Mesa Street, Suite 200 Fax: (303) 844-6676
El Paso, TX 79912-5936 Vermont
(915) 534-6251 http://labor.vermont.gov/
Fax: (915) 534-6259 There are no area offices in Vermont.
Fort Worth Area Office Contact the regional office in Boston, MA
North Starr II, Suite 302 at:
8713 Airport Freeway JFK Federal Building, Room E340
Fort Worth, TX 76180-7610 Boston, MA 02203
(817) 428-2470 (617) 565-9860
Fax: (817) 581-7723 Fax: (617) 565-9827
Houston North Area Office Virginia
690 S. Loop 336 W., Suite 400 www.doli.virginia.gov/
Conroe, TX 77304 Norfolk Area Office
(936) 760-3800 Federal Office Building, Room 614
Houston South Area Office 200 Granby St.
17625 El Camino Real, Suite 400 Norfolk, VA 23510-1811
Houston, TX 77058 (757) 441-3820
(281) 286-0583 Fax: (757) 441-3594
(800) 692-4202 Virgin Islands
Fax: (281) 286-6352 There are no area offices in the Virgin
Lubbock District Office Islands. Contact the regional office in New
1205 Texas Avenue, Room 806 York, NY at:
Lubbock, TX 79401 201 Varick Street, Room 670
(806) 472-7681/7685 New York, NY 10014
Fax: (806) 472-7686 (212) 337-2378
Fax: (212) 337-2371
San Antonio District Office
Fountainhead Tower, Suite 605 Washington
8200 W. Interstate 10 www.lni.wa.gov/wisha
San Antonio, TX 78230 Bellevue Area Office
(210) 472-5040 520 112th Avenue, NE, Suite 200
Fax: (210) 472-5045 Bellevue, WA 98004
(425) 450-5480
Fax: (425) 450-5483

West Virginia
www.wvminesafety.org/
Charleston Area Office
405 Capitol Street, Suite 407
Charleston, WV 25301-1727
(304) 347-5937
Fax: (304) 347-5275
Wisconsin
http://dwd.wisconsin.gov/
Appleton Area Office
1648 Tri Park Way
Appleton, WI 54914
(920) 734-4521
Fax: (920) 734-2661
Eau Claire Area Office
1310 West Clairemont Avenue
Eau Claire, WI 54701
(715) 832-9019
Fax: (715) 832-1147
Madison Area Office
4802 East Broadway
Madison, WI 53716
(608) 441-5388
Fax: (608) 441-5400
Milwaukee Area Office
310 West Wisconsin Avenue, Room 1180
Milwaukee, WI 53203
(414) 297-3315
Fax: (414) 297-4299
Wyoming
http://wyomingworkforce.org/Pages/
default.aspx
There are no area offices in Wyoming.
Contact the regional office in Denver, CO
at:
Herb Gibson, Area Director
U.S. Department of Labor
Occupational Safety and Health
Administration
1391 Speer Blvd., Suite 210
Denver, CO 80204-2552
(303) 844-5285, Ext.106

OSHA Regional Offices

If you are unable to contact your local OSHA Area Office, you may contact the appropriate
OSHA Regional Office for information and/or assistance. These addresses are current as of
August 7, 2014.
Region I Region VI
(CT* MA, ME, NH, RI, VT*) (AR, LA, NM,* OK, TX)
JFK Federal Building, Room E340 525 Griffin Street, Suite 602
Boston, MA 02203 Dallas, TX 75202
(617) 565-9860 (972) 850-4145
Fax: (617) 565-9827 Fax: (972) 850-4149
Region VII
Region II
(IA,* KS, MO, NE)
(NJ, NY, Puerto Rico, Virgin Islands)* Two Pershing Square Building
201 Varick Street, Room 670 2300 Main Street, Suite 1010
New York, NY 10014 Kansas City, MO 64108-2416
(212) 337-2378 (816) 283-8745
Fax: (212) 337-2371 Fax: (816) 283-0547
Region III Region VIII
(DC, DE, MD,* PA, VA,* WV) (CO, MT, ND, SD, UT,* WY*)
U.S. Department of Labor/OSHA Cesar Chavez Memorial Building
The Curtis Center—Suite 740 West 1244 Speer Blvd., Suite 551
170 S. Independence Mall West Denver, CO 80204
Philadelphia, PA 19106-3309 (720) 264-6550
(215) 861-4900 Fax: (720) 264-6585
Fax: (215) 861-4904 Region IX
Region IV (American Samoa, AZ,* CA,* Guam, HI,*
(AL, FL, GA, KY,* MS, NC,* SC,* TN*) NV,* Trust Territories of the Pacific)
61 Forsyth Street SW 90 7th Street, Suite 18100
Room 6T50 San Francisco, CA 94103
Atlanta, GA 30303 (415) 625-2547 (Main Public — 8:00 AM -
(678) 237-0400 4:30 PM Pacific)
Fax: (678) 237-0447 Fax: (415) 625-2534
Region V Region X
(IL,* IN,* MI,* MN,* OH, WI) (AK,* ID, OR,* WA*)
230 South Dearborn Street, Room 3244 300 Fifth Avenue, Suite 1280
Chicago, IL 60604 Seattle, WA 98104-2397
(312) 353-2220 (206) 757-6700
Fax: (312) 353-7774 Fax: (206) 757-6705
*These states and territories operate their own OSHA-approved job safety and health
programs (Connecticut, Illinois, New Jersey, New York, and Virgin Islands plans cover public
employees only). States with approved programs must have a standard that is identical to,
or at least as effective as, the federal standard.

OSHA District Offices

Note: Not all OSHA Regions have a district office. This information is current as of August
4, 2014.
Region I Region VI
(CT,* MA, ME, NH, RI, VT*) (AR, LA, NM,* OK, TX)
JFK Federal Bldg., Rm. E340 525 Griffin St., Ste. 602
Boston, MA 02203 Dallas, TX 75202
(617) 565-9860 (972) 850-4145
Fax: (617) 565-9827 Fax: (972) 850-4149
Region II Region VII
(NJ, NY,* PR,* VI*) (IA,* KS, MO, NE)
201 Varick St., Rm. 670 Two Pershing Square Building
New York, NY 10014 2300 Main St., Ste. 1010
(212) 337-2378 Kansas City, MO 64108-2416
Fax: (212) 337-2371 (816) 283-8745
Fax: (816) 283-0547
Region III
(DC, DE, MD,* PA, VA,* WV) Region VIII
U.S. Department of Labor/OSHA (CO, MT, ND, SD, UT,* WY*)
The Curtis Center, Ste. 740 W Cesar Chavez Memorial Building
170 S. Independence Mall W 1244 Speer Blvd., Suite 551
Philadelphia, PA 19106-3309 Denver, CO 80204
(215) 861-4900 (720) 264-6550
Fax: (215) 861-4904 Fax: (720) 264-6585
Region IV Region IX
(AL, FL, GA, KY,* MS, NC,* SC,* TN*) (American Samoa, AZ,* CA,* Guam, HI,*
61 Forsyth St., SW NV,* Trust Territories of the Pacific)
Room 6T50 90 7th St., Ste. 18100
Atlanta, GA 30303 San Francisco, CA 94103
(678) 237-0400 (415) 625-2547
Fax: (678) 237-0447 Fax: (415) 625-2534
Region V Region X
(IL, IN,* MI,* MN,* OH, WI) (AK,* ID, OR,* WA*)
230 S Dearborn St., Rm. 3244 300 Fifth Ave., Ste. 1280
Chicago, IL 60604 Seattle, WA 98104-2397
(312) 353-2220 (206) 757-6700
Fax: (312) 353-7774 Fax: (206) 757-6705
* These states and territories operate their own OSHA-approved job safety and health
programs (Connecticut, Illinois, New Jersey, New York, and Virgin Islands plans cover public
employees only). States with approved programs must have a standard that is identical to,
or at least as effective as, the Federal standards.

States With OSHA-Approved Programs

The OSH Act encourages states to develop and operate their own job safety and health
programs. Federal OSHA approves and monitors state plans and provides up to 50 percent
of an approved plan’s operating costs. There are currently 22 states and jurisdictions
operating complete state plans (covering both the private sector and state and local gov-
ernment employees) and five states which cover public employees only. The following
information is current as of August 7, 2014.
Alaska Hawaii
http://labor.state.ak.us/lss/home.htm http://labor.hawaii.gov/hiosh/
Alaska Department of Labor & Workforce Hawaii Department of Labor and Industrial
Development Relations
1111 W 8th Street, Room 304 Hawaii Occupational Safety and Health
P.O. Box 111149 Division (HIOSH)
Juneau, AK 99811-1149 830 Punchbowl Street, Suite 423
(907) 465-4855 Honolulu, HI 96813
(808) 586-9100
Arizona
www.ica.state.az.us/ADOSH/ Illinois
ADOSH_main.aspx www.illinois.gov/idol/Pages/default.aspx
Arizona Division of Occupational Safety Illinois Department of Labor
and Health (ADOSH) 900 S. Spring Street
800 W Washington Street, 2nd floor Springfield, IL 62704
Phoenix, AZ 85007-2922 (217) 782-6206
(602) 542-5795 Indiana
California www.in.gov/dol/iosha.htm
www.dir.ca.gov/occupational_safety.html Indiana Department of Labor
California Department of Industrial 402 West Washington Street, Room W195
Relations (DIR) Indianapolis, IN 46204
Division of Occupational Safety and Health (317) 232-2693
1515 Clay Street Suite 1901 Iowa
Oakland, CA 94612
(510) 286-7000 www.iowaworkforce.org/labor/iosh/
index.html
Connecticut Iowa Division of Labor Services and
www.ctdol.state.ct.us/osha/osha.htm Workforce Development
Connecticut Department of Labor 1000 East Grand Avenue
200 Folly Brook Boulevard Des Moines, IA 50319-0209
Wethersfield, CT 06109 (515) 242-5870
(860) 263-6000
Conn-OSHA
38 Wolcott Hill Road
Wethersfield, CT 06109
(860) 263-6900

Kentucky Nevada
www.labor.ky.gov/dows/oshp/Pages/ http://dirweb.state.nv.us/OSHA/osha.htm
Occupational-Safety-and-Health- Nevada Division of Industrial Relations
Program.aspx Occupational Safety and Health
Kentucky Occupational Safety and Health Administration
Program 1301 North Green Valley Parkway, Suite
1047 U.S. Highway 127 South, Suite 4 200
Frankfort, KY 40601 Henderson, Nevada 89074
(502) 564-3070 (702) 486-9020
Maryland New Jersey
www.dllr.state.md.us/labor/mosh.html http://lwd.dol.state.nj.us/labor/lsse/
Department of Labor, Licensing and employer/Public_Employees_OSH.html
Regulation New Jersey Department of Labor and
Division of Labor and Industry Workforce Development
Maryland Occupational Safety and Health Public Employees Occupational Safety and
(MOSH) Health (PEOSH) Office
10946 Golden West Drive, Suite 160 1 John Fitch Plaza
Hunt Valley, MD 21031 P.O. Box 110
(410) 527-4499 Trenton, NJ 08625-0110
Michigan (609) 633-3896
www.michigan.gov/lara/0,4601,7-154- New Mexico
61256_11407---,00.html www.nmenv.state.nm.us/Ohsb_Website/
Michigan Department of Licensing and index.htm
Regulatory Affairs (LARA) New Mexico Environment Department
Michigan Occupational Safety & Health Occupational Safety and Health Bureau
Administration (MIOSHA) 525 Camino de los Marquez, Suite 3
P.O. Box 30643 Santa Fe, NM 87502
7150 Harris Drive (505) 476-8700
Lansing, MI 48909-8143
(517) 322-1814 New York
Minnesota www.labor.state.ny.us/workerprotection/
safetyhealth/DOSH_PESH.shtm
www.dli.mn.gov/MnOsha.asp NYS Department of Labor
Minnesota Department of Labor and Public Employees Safety and Health
Industry (PESH) Bureau
Minnesota OSHA Compliance W.A. Harriman Campus
443 Lafayette Road North Building 12, Room 158
St. Paul, MN 55155 Albany, NY 12240
(651) 284-5050 (518) 457-1263
North Carolina
www.nclabor.com/osha/osh.htm
North Carolina Department of Labor
Occupational Safety and Health Division
1101 Mail Service Center
Raleigh, NC 27699-1101
(919) 807-2900

Oregon Vermont
www.orosha.org/ http://labor.vermont.gov/vosha/
Oregon Occupational Safety and Health Vermont Department of Labor and Industry
Division (Oregon OSHA) 5 Green Mountain Drive
Department of Consumer and Business P.O. Box 488
Services Montpelier, VT 05601-0488
350 Winter Street NE, Room 430 (802) 828-4000
P.O. Box 14480 Virgin Islands
Salem, OR 97309-0405 www.vidol.gov/Units/OSHA/OSHA.htm
(503) 378-3272 Virgin Islands Department of Labor
(VIDOSH)
Puerto Rico St. Croix Main Office
www.trabajo.pr.gov/prosha/index.asp 3012 Golden Rock, VITRACO Mall
Puerto Rico Occupational Safety and St. Croix, VI 00890
Health Administration (PR OSHA) (340) 772-1315
P.O. Box 195540 St. Thomas Main Office
San Juan, PR 00919-5540 53A & 54B Kronprindense Gade
(787) 754-2172 St. Thomas, VI 00803-2608
South Carolina (340) 776-3700
www.scosha.llronline.com/ Virginia
South Carolina Department of Labor, www.doli.virginia.gov/
Licensing and Regulation Virginia Department of Labor and Industry
South Carolina OSHA Main Street Centre Bldg.
P.O. Box 11329 600 East Main Street
Columbia, S.C. 29211 Richmond, VA 23219-4101
(803) 896-7665 (804) 371-2327
Tennessee Washington
www.tn.gov/labor-wfd/tosha.shtml www.lni.wa.gov/Safety/default.asp
Department of Labor and Workforce Washington Department of Labor and
Development Industries
TOSHA Division of Occupational Safety & Health
220 French Landing Drive (DOSH)
Nashville, TN 37243-0655 P.O. Box 44600
(615) 741-2793 Olympia, WA 98504-4600
Utah (360) 902-5494
www.laborcommission.utah.gov/divisions/ Wyoming
UOSH/index.html http://wyomingworkforce.org/employers-
Utah Labor Commission and-businesses/osha/Pages/default.aspx
Utah OSHA Wyoming Workers Safety and
160 East 300 South, 3rd Floor Compensation Division
P.O. Box 146600 1510 East Pershing Boulevard, West Wing
Salt Lake City, UT 84114-6600 Cheyenne, WY 82002
(801) 530-6901 (307) 777-7786
Note: Connecticut, Illinois, New Jersey, New York, and the Virgin Islands plans cover public
employees only.

OSHA Consultation Services

These addresses are current as of August 6, 2014.
Alabama California
http://webdev-alabamasafestate.ua.edu/ https://www.dir.ca.gov/dosh/
safety-consultation/ consultation.html
Safe State Program Cal/OSHA Consultation
University of Alabama Division of Occupational Safety and Health
432 Martha Parham West, Rm 432 2000 E. McFadden Ave., Rm. 214
P.O. Box 870388 Santa Ana, CA 92705
Tuscaloosa, AL 35487-0388 (714) 558-4411
(205) 348-7136 or (800) 452-5928 (in Fax: (916) 558-4431
Alabama only) Cal/OSHA Consultation Service Area
Fax: (205) 348-9286 Offices
Alaska Cal/OSHA Consultation toll-free number -
www.labor.state.ak.us/lss/oshhome.htm (800) 963-9424
Alaska Occupational Safety and Health Northern California - (916) 263-0704
Consultation and Training San Fernando Valley - (818) 901-5754
3301 Eagle St., Rm 305 San Francisco Bay Area - (510) 622-2891
Anchorage, AK 99503-4149 Los Angeles/Orange - (714) 562-5525
(800) 656-4972 San Diego - (619) 767-2060
Fax: (907) 269-4950 Central Valley - (559) 454-1295
San Bernardino - (909) 383-4567
Arizona
Colorado
www.ica.state.az.us/ADOSH/
ADOSH_Consultation_and_Training.aspx www.bernardino.colostate.edu/public/
Consultation and Training Occupational Health & Safety Consultation
Industrial Commission of Arizona Colorado State University
Arizona Division of Occupational Safety & 1681 Campus Delivery
Health (ADOSH) Fort Collins, CO 80523-1681
2675 E. Broadway Rd., Ste. 239 (970) 491-6151
Tucson, AZ 85716 Fax: (970) 491-7778
(520) 628-5478 Connecticut
Fax: (520) 322-8008 www.ctdol.state.ct.us/osha/consulti.htm
Arkansas Connecticut Department of Labor
www.labor.ar.gov/divisions/Pages/ Division of Occupational Safety & Health
OSHAConsultation.aspx 38 Wolcott Hill Rd.
OSHA Consultation Wethersfield, CT 06109
Arkansas Department of Labor (860) 263-6900
10421 W. Markham Fax: (860) 263-6940
Little Rock, AR 72205
(501) 682-4522
Fax: (501) 682-4532

Delaware Guam
http://dia.delawareworks.com/safety-health- http://www.dol.guam.gov/content/
consultation/ occupational-safety-and-health-
Delaware Department of Labor administration-osha-site-consultation
Office of Safety & Health Guam Department of Labor
Division of Industrial Affairs OSHA Onsite Consultation Program
4425 N. Market St. 414 West Soledad Ave.
Wilmington, DE 19802 GCIC Bldg., 4th Fl.
(302) 761-8225 Hagatna, Guam 96910
District of Columbia (671) 300-4582
http://does.dc.gov/service/occupational- Fax: (671) 475-6811
safety-and-health Hawaii
Available only for employers within the
http://labor.hawaii.gov/hiosh/home/for-
District of Columbia
employers/consultation/
D.C. Department of Employment Services
Labor Standards Bureau Consultation & Training Branch
Office of Occupational Safety & Health Department of Labor & Industrial Relations
4058 Minnesota Ave., NE 830 Punchbowl St., #423
Washington, DC 20019 Honolulu, HI 96813
(202) 671-1800 (808) 586-9100
Fax: (202) 673-2380 Fax: (808) 586-9104
Florida Idaho
www.usfsafetyflorida.com/ http://oshcon.boisestate.edu/
Safety Florida Consultation Program OSHCon
University of South Florida Boise State University
13201 Bruce B. Downs Blvd., MDC 56 1910 University Dr., MS-1825
Tampa, FL 33612 Boise, ID 83725-1825
(866) 273-1105 (208) 426-3283
Fax: (813) 974-8270 Fax: (208) 426-4411
Georgia Illinois
www.oshainfo.gatech.edu/ www.illinoisosha.com/
21(d) Onsite Consultation Program Illinois On-site Consultation
Georgia Institute of Technology Illinois Department of Labor
260 14th St., NW 900 S. Spring St.
North Building Springfield, IL 62704
Atlanta, GA 30332-0837 (217) 782-1442
(404) 407-8276 Fax: (217) 785-0596
Fax: (404) 407-9024
Indiana
www.in.gov/dol/2375.htm
INSafe
Indiana Department of Labor
402 W. Washington St., W195
Indianapolis, IN 46204
(317) 232-2655
Fax: (317) 233-3790

Iowa Maine
www.iowaworkforce.org/labor/iosh/ www.safetyworksmaine.com/consultations
consultation/index.htm SafetyWorks!
Iowa Workforce Development Maine Department of Labor
Division of Labor Services 45 State House Station
OSHA Consultation & Education Augusta, ME 04333-0045
1000 E. Grand Ave. (207) 623-7900 or toll-free (877) 723-3345
Des Moines, IA 50319 Maryland
(515) 281-7629 www.dllr.state.md.us/labor/mosh/volc.shtml
Fax: (515) 281-5522 MOSH Consultation Services
Kansas 10946 Golden West Dr., Ste. 160
www.dol.ks.gov/Safety/assistance.aspx Hunt Valley, MD 21031
(410) 527-4472
Kansas Department of Labor
Fax: (410) 527-5678
Industrial Safety & Health
417 S.W. Jackson St. Massachusetts
Topeka, KS 66603-3327 www.mass.gov/lwd/labor-standards/on-site-
(785) 296-4386, ext. 2310 consultation-program/
Fax: (785) 296-1775 Massachusetts Department of Labor
Kentucky Standards
OSHA Consultation Program
www.labor.ky.gov/dows/oshp/Pages/ Wall Experiment Station
Occupational-Safety-and-Health- 37 Shattuck St.
Program.aspx Lawrence, MA 01843
Kentucky Occupational Safety and Health (617) 626-6504
Program Fax: (978) 688-0352
1047 U.S. Hwy. 127 South, Ste. 4
Frankfort, KY 40601 Michigan
(502) 564-3070 www.michigan.gov/lara/0,4601,7-154-
Fax: (502) 696-1902 61256_11407---,00.html
Louisiana Consultation Education & Training Division
Michigan Occupational Safety and Health
wwwprd.doa.louisiana.gov/LaServices/ Administration
PublicPages/ServiceDetail.cfm?service_id= Labor & Economic Growth
2320 7150 Harris Dr.
21(d) Consultation Program P.O. Box 30643
Louisiana Department of Labor Lansing, MI 48909-8413
OSHA Consultation, Office of Workers’ (517) 322-1809
Compensation (800) 866-4674
1001 North 23rd Street Fax: (517) 322-1374
Baton Rouge, LA 70804-9094
(225) 342-7561 Minnesota
Fax: (225) 342-5665 www.doli.state.mn.us/Wsc.asp
Minnesota Department of Labor & Industry
Consultation Division
443 Lafayette Rd. North
St. Paul, MN 55155
(651) 284-5060
Fax: (651) 284-5739

Mississippi New Hampshire

www.csh.msstate.edu/ http://www.keene.edu/conted/workwisenh/
Mississippi State University WorkWISE NH
Center for Safety & Health Keene State College
2151 Hwy. 18, Ste. B Rhodes Hall, M-3925
Brandon, MS 39042 229 Main St.
(601) 825-0783 Keene, NH 03101
Fax: (601) 825-6609 (603) 358-2411
Fax: (603) 358-2399
Missouri
New Jersey
http://labor.mo.gov/onsite
Division of Labor Standards http://lwd.dol.state.nj.us/labor/lsse/
On-Site Safety and Health Program employer/peosh_consultation.html
3315 W. Truman Blvd., Room 205 New Jersey Department of Labor and
P.O. Box 449 Workforce Development
Jefferson City, MO 65102-0499 Division of Public Safety & Occupational
(573) 522-SAFE (7233) Safety & Health
Fax: (573) 751-3721 OSHA On-Site Consultation & Training
One John Fitch Plaza
Montana P.O. Box 953
http://erd.dli.mt.gov/safety-health/onsite- Trenton, NJ 08625-0953
consultation/onsite-consultation (609) 984-0785
Montana Department of Labor & Industry Fax: (609) 292-4409
Safety & Health Bureau New Mexico
P.O. Box 1728
Helena, MT 59624-1728 www.nmenv.state.nm.us/Ohsb_Website/
(406) 444-6401 Consultation/
Fax: (406) 444-9696 New Mexico Environment Department
Occupational Health & Safety Bureau
Nebraska 525 Camino de Los Marquez Suite 3
www.dol.nebraska.gov/ Santa Fe, NM 87502
center.cfm?PRICAT=2&SUBCAT=1H (505) 476-8720
Nebraska Department of Labor - OSHA (877) 610-6742
Consultation Fax: (505) 476-8734
550 S 16th St. New York
P.O. Box 94600
Lincoln, NE 68509-4600 www.labor.state.ny.us/workerprotection/
(402) 471-4717 safetyhealth/
Fax: (402) 471-4728 DOSH_ONSITE_CONSULTATION.shtm
New York State Department of Labor On-
Nevada site Consultation
www.4safenv.state.nv.us/consultation 109 S. Union Street Room 402
Safety Consultation & Training Section Rochester, NY 14607
Division of Industrial Relations (716) 847-7168
Department of Business & Industry Fax: (716) 847-7926
1301 N. Green Valley Pkwy., Ste. 200
Henderson, NV 89074
(702) 486-9140
Fax: (702) 990-0362

North Carolina Oregon

www.nclabor.com/osha/consult/consult.htm www.orosha.org
Bureau of Consultative Services Oregon OSHA Consultation and Services
NC Department of Labor Department of Consumer & Business
1101 Mail Service Center Services
Raleigh, NC 27699-1101 350 Winter St., Northeast, Rm. 430
(919) 807-2899 Salem, OR 97301-3882
Fax: (919) 807-2902 (503) 947-7434
Fax: (503) 947-7462
North Dakota
www.bismarckstate.edu/ceti/ndosh/ Pennsylvania
North Dakota Occupational Safety & www.iup.edu/pa-oshaconsultation
Health Indiana University of Pennsylvania
Consultation - Bismarck State College Room 210 Walsh Hall
Corporate & Continuing Education 302 East Walk
1500 Edwards Avenue Indiana, PA 15705-1087
PO Box 5587 (724) 357-2396
Bismarck, ND 58516-5587 (800) 382-1241
(701) 224-5400 Fax: (724) 357-2385
(800) 445-5073 Puerto Rico
Fax: (701) 224-5763
www.trabajo.pr.gov/prosha/
Ohio Puerto Rico Occupational Safety and
www.bwc.ohio.gov/employer/programs/ Health Office Administration
safety/SandHOSHAandPERRP.asp Department of Labor & Human Resources
Ohio Bureau of Workers’ Compensation 21st Fl.
Division of Safety and Hygiene 505 Munoz Rivera Ave.
OSHA On-Site Consultation Program Hato Rey, Puerto Rico 00918
13430 Yarmouth Dr. (787) 754-2171
Pickerington, OH 43147 Fax: (787) 767-6051
(800) 282-1425 Rhode Island
Fax: (614) 644-3133
www.health.ri.gov/programs/
Oklahoma oshaconsultation/
www.ok.gov/odol/Business_Services/ OSH Consultation Program
Safety_Pays_OSHA_Consultation/ Division of Occupational Health &
index.html Radiation Control
Oklahoma Department of Labor Rhode Island Department of Health
OSHA Consultation Division 3 Capitol Hill
3017 N. Stiles, Ste. 100 Cannon Building, Room 206
Oklahoma City, OK 73105-5212 Providence, RI 02908
(405) 521-6139 (401) 222-7745
Fax: (405) 521-6020 Fax: (401) 222-2456

South Carolina Utah

www.scosha.llronline.com/index.asp?file= http://laborcommission.utah.gov/divisions/
scovp/consult.htm UOSH/index.html
South Carolina Department of Labor, Utah OSHA Consultation Program
Licensing and Regulation 160 E. 300 South, 3rd Fl.
110 Centerview Dr. Salt Lake City, UT 84114-6650
PO Box 11329 (801) 530-6855
Columbia, SC 29211-1329 Fax: (801) 530-6992
(803) 896-7787 Vermont
Fax: (803) 896-7750 http://labor.vermont.gov/vosha/
South Dakota Vermont Department of Labor
www.sdstate.edu/engr/extension/index.cfm Workers’ Compensation and Safety
South Dakota State University Division
PO Box 488, 5 Green Mountain Dr.
Engineering Extension - OSHA
Montpelier, VT 05601-0488
Consultation (802) 888-2598
SHH 201, Box 2220 Fax: (802) 828-2195
Brookings, SD 57007-0597
(605) 688-5741 Virginia
Fax: (605) 688-6290 www.doli.virginia.gov/
Tennessee Virginia Department of Labor & Industry
Occupational Safety & Health
www.tn.gov/labor-wfd/tosha/toshcons.shtml Training & Consultation
TOSHA Consultation Services Main Street Centre Building, 600 East Main
Tennessee Department of Labor and Street,
Workforce Development Suite 207
TOSHA/Consultation Richmond, VA 23219-4101
220 French Landing Dr. (804) 786-6613
Nashville, TN 37243 Fax: (804) 786-8418
(800) 325-9901
Fax: (615) 532-2997 Virgin Islands
Texas www.vidol.gov
Safety in Paradise
www.tdi.texas.gov/oshcon/index.html University of the Virgin Islands
Workers’ Health and Safety Division - MS Community Engagement and Lifelong
22 Learning Center
Texas Department of Insurance #2 John Brewer’s Bay
7551 Metro Center Dr. St. Thomas, Virgin Islands 00803
Austin, TX 78744-1609 (340) 693-1100
(512) 804-4640 Fax: (340) 693-1115
Fax: (512) 804-4641
OSHCON Request Line: (800) 687-7080 Washington
http://lni.wa.gov/Safety/Consultation/
About.asp
WISHA Services Division
P.O. Box 4648
Olympia, WA 98504-4648
(360) 902-5554
Fax: (360) 902-5438

West Virginia
www.wvlabor.com/newwebsite/Pages/
Safety_osha_consultation.html
West Virginia Department of Labor
WISHA Services Division
Capitol Complex Building #6
1800 E. Washington Street, Rm. B-749
Charleston, WV 25305
(304) 558-7890
Fax: (360) 902-5438
Wisconsin
www.slh.wisc.edu/occupational/wiscon/
University of Wisconsin State Laboratory of
Hygiene
2601 Agriculture Dr.
P.O. Box 7996
Madison, WI 53707-7996
(608) 226-5240
(800) 947-0553
Fax: (608) 226-5249
Wyoming
www.wyomingworkforce.org/employers-
and-businesses/osha/Pages/safety-and-
health-consultation.aspx
Wyoming Department of Workforce
Services OSHA Division
1510 E. Pershing Blvd., West Wing
Cheyenne, WY 82002
(307) 777-7710
Fax: (307) 777-3646

Association Addresses
Current as of August 5, 2014.
Alliance of Hazardous Materials American Institute of Chemical
Professionals (AHMP) Engineers (AICE)
www.ahmpnet.org www.aiche.org
9650 Rockville Pike 120 Wall St. Fl. 23
Bethesda, MD 20814 New York, NY 10005-4020
(800) 437-0137 (toll-free) (800) 242-4363
(301) 634-7430 (203) 702-7660 (outside the U.S.)
Fax: (301) 634-7431 Fax: (203) 775-5177
American Chemistry Council (ACC) American National Standards Institute
www.americanchemistry.com (ANSI)
700 2nd St., Northeast www.ansi.org
Washington, DC 20002 1899 L St., NW, 11th Fl.
(202) 249-7000 Washington, DC 20036
Fax: (202) 249-6100 (202) 293-8020
American Chemical Society (ACS) Fax: (202) 293-9287
www.acs.org or
1155 16th St., Northwest 25 W 43rd St., 4th Fl.
Washington, DC 20036 New York, NY 10036
(800) 227-5558 (US only) (212) 642-4900
(202) 872-4600 (Worldwide) Fax: (212) 398-0023
American Conference of Governmental American Petroleum Institute (API)
Industrial Hygienists (ACGIH) www.api.org
www.acgih.org 1220 L St., Northwest
1330 Kemper Meadow Dr. Washington, DC 20005-4070
Cincinnati, OH 45240 (202) 682-8000
(513) 742-2020 (customers/members) American Society of Heating,
(513) 742-6163 (administrative phone) Refrigerating and Air-Conditioning
Fax: (513) 742-3355 Engineers
American Industrial Hygiene www.ashrae.org
Association (AIHA) 1791 Tullie Circle, Northeast
www.aiha.org Atlanta, GA 30329
3141 Fairview Park Dr., Ste. 777 (800) 527-4723 (U.S. and Canada only)
Falls Church, VA 22042 (404) 636-8400
(703) 849-8888 Fax: (404) 321-5478
Fax: (703) 207-3561 American Society for Testing and
Materials (ASTM)
www.astm.org
100 Barr Harbor Dr.
P.O. Box C700
West Conshohocken, PA 19428-2959
(877) 909-2786 (U.S. and Canada only)
(610) 832-9585 (International)

American Society of Agricultural and Compressed Gas Association (CGA)

Biological Engineers (ASABE) www.cganet.com
www.asabe.org 14501 George Carter Way, Ste. 103
2950 Niles Rd. Chantilly, VA 20151-2923
St. Joseph, MI 49085 (703) 788-2700
(269) 429-0300 Fax: (703) 961-1831
Fax: (269) 429-3852 International Agency for Research on
American Society of Mechanical Cancer (IARC)
Engineers (ASME) www.iarc.fr
www.asme.org 150 Cours Albert Thomas
2 Park Ave. 69372 Lyon CEDEX 08
New York, NY 10016-5990 France
(800) 843-2763 (U.S. and Canada) +33 (0)4 72 73 84 85
001-800-843-2763 (Mexico) Fax: +33 (0)4 72 73 85 75
(973) 882-1170 (outside North America) International Safety Equipment
American Society of Safety Engineers Association
(ASSE) www.safetyequipment.org
www.asse.org 1901 N Moore St.
1800 E Oakton St. Arlington, VA 22209-1762
Des Plaines, IL 60018 (703) 525-1695
(847) 699-2929 Fax: (703) 528-2148
Fax: (847) 768-3434 National Association of Manufacturers
American Welding Society (AWS) (NAM)
www.aws.org www.nam.org
8669 NW 36 St., Ste. 130 733 10th St. Northwest, Ste. 700
Miami, FL 33166-6672 Washington, DC 20001
(800) 443-9353 (800) 814-8468
(305) 443-9353 (202) 637-3000 (in Washington, DC)
Fax: (202) 637-3182
Chemical Abstract Service (CAS)
National Fire Protection Association
www.cas.org
(NFPA)
P.O. Box 3012
Columbus, OH 43210 www.nfpa.org
(800) 848-6538 (North America only) 1 Batterymarch Park
(614) 447-3600 (worldwide) Quincy, MA 02169-7471
Fax: (614) 447-3713 (617) 770-3000
Fax: (617) 770-0700
Council of Producers & Distributors of
Agrotechnology National Safety Council
Formerly known as Chemical Producers www.nsc.org
and Distributors Association 1121 Spring Lake Dr.
Itasca, IL 60143-3201
http://cpda.com/ (800) 621-7615
1730 Rhode Island Ave., Ste. 812 (630) 285-1121
Washington, DC 20036 Fax: (630) 285-1315
(202) 386-7407
Fax: (202) 386-7409

National Waste & Recycling Association

https://wasterecycling.org/
4301 Connecticut Ave., Northwest, Ste.
300
(800) 424-2869
(202) 244-4700
Fax: (202) 966-4824
Society of Automotive Engineers (SAE)
www.sae.org
SAE International
400 Commonwealth Dr.
Warrendale, PA 15096-0001
(877) 606-7323 (U.S. and Canada)
(724) 776-4970 (Outside U.S. and Canada)
Fax: (724) 776-0790
Society for Chemical Hazard
Communication (SCHC)
www.schc.org
P.O. Box 1392
Annandale, VA 22003-9392
(703) 658-9246
Fax: (703) 658-9247
Society of Chemical Manufacturers &
Affiliates (SOCMA)
Formerly known as Synthetic Organic
Chemical Manufacturers Association
www.socma.com
1850 M St. NW, Ste. 700
Washington, DC 20036-5810
(202) 721-4100
Fax: (202) 296-8120

Other Relevant Addresses

Current as of August 7, 2014.
Occupational Safety and Health Administration (OSHA)
United States Department of Labor
200 Constitution Avenue, NW
(800) 321-6742
OSHA Enforcement Programs
Directorate of Enforcement Programs (DEP)
U.S. Dept. of Labor, OSHA
200 Constitution Avenue, NW, RM N-3119
(202) 693-2100
OSHA Training Institute
OSHA Directorate of Training and Education
2020 South Arlington Heights Road
Arlington Heights, IL 60005-4102
(847) 759-7700
National Institute for Occupational Safety and Health (NIOSH)
Education and Information Division (EID)
Mailstop C14
4676 Columbia Parkway
Cincinnati, OH 45226
(513) 533-8302
National Toxicology Program
Office of Liasion, Policy and Review
PO Box 12233, MD K2-03
Research Triangle Park, NC 27709
(919) 541-0530
(919) 541-3419 (Central Data Management)
Cincinnati Technical Center
Formerly Cincinnati Laboratory
(Technical equipment calibration and repair)
435 Elm Street, Suite 500
Cincinnati, OH 45202-2673
(513) 684-3721
Salt Lake City Laboratory
(Chemical analyses of monitoring samples)
Salt Lake Technical Center
8660 South Sandy Parkway
Sandy, UT 84070-6424
(801) 233-4900

World Health Organization (WHO)

Regional Office of the Americas
525 23rd Street, NW
(202) 974-3000

Index
Numerics
300 Log
I/J/K, Injury and Illness Recordkeeping ...............................................................10
300A Summary
I/J/K, Injury and Illness Recordkeeping.................................................................1
301 Incident Report
A
Abrasive Wheel Machinery
I/J/K, Inspections .........................................................................................41
Acrylontrile
I/J/K, Inspections .........................................................................................59
AEDs
A, AEDs......................................................................................................1
Aerial Lifts
A, Aerial Lifts................................................................................................1
Agency Addresses
Reference, Agency Contacts ................................................1, 10, 11, 12, 15, 22, 25
Association Addresses
Reference, Agency Contacts ...........................................................................22
OSHA Consultation Services
OSHA District Offices
OSHA Local Area Offices
Reference, Agency Contacts ............................................................................1
OSHA Regional Offices
Other Relevant Addresses
Air Monitoring
C, Confined Spaces........................................................................................1
Aisles and Walkways
A, Aisles and Walkways...................................................................................1
Alternate Entry
9/14 Index-1
Anchoring
M/N, Machine Guarding ...................................................................................1
S, Storage Racks...........................................................................................1
Asbestos
I/J/K, Inspections .........................................................................................57
Associations
Association Contact Information
Audits
R, Recordkeeping ..........................................................................................1
Automated External Defibrillators
A, AEDs......................................................................................................1
B
Back Belts
E, Ergonomics ..............................................................................................1
Bakery Equipment
I/J/K, Inspections .........................................................................................46
Battery Charging
E, Emergency Eyewashes and Showers ...............................................................3
P/Q, Powered Industrial Trucks ..........................................................................1
B, Bloodborne Pathogens.................................................................................1
F/G, First Aid ................................................................................................1
I/J/K, Inspections .........................................................................................58
R, Recordkeeping ..........................................................................................1
C
Cages and Wells
F/G, Fixed Ladders.........................................................................................1
Cardiopulmonary Resuscitation
F/G, First Aid ................................................................................................2
Coke Oven Emissions
I/J/K, Inspections .........................................................................................57
Commercial Diving
I/J/K, Inspections .........................................................................................56
Equipment
I/J/K, Inspections .........................................................................................56
Index-2 9/14
Pre-Dive Procedures
I/J/K, Inspections .........................................................................................56
Compressed Gas Cylinders
C, Compressed Gases ....................................................................................1
Compressed Gases
C, Compressed Gases ....................................................................................1
I/J/K, Inspections..........................................................................................11
Confined Spaces
Contractors
E, Electric Power Generation, Transmission, and Distribution ......................................1
L, Lockout/Tagout ..........................................................................................1
CPR
F/G, First Aid ................................................................................................2
Cranes
I/J/K, Inspections .....................................23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34
Crawler Locomotive and Truck Cranes
I/J/K, Inspections .........................................................................................29
Overhead and Gantry Cranes
I/J/K, Inspections .........................................................................................23
Recordkeeping
I/J/K, Inspections ...............................................24, 25, 26, 27, 28, 30, 31, 32, 33, 34
D
Days Away
Derricks
I/J/K, Inspections..................................................................35, 36, 37, 38, 39, 40
Recordkeeping
I/J/K, Inspections ......................................................................36, 37, 38, 39, 40
Dipping and Coating Operations
I/J/K, Inspections .........................................................................................15
Drill Presses
E
EAP
E, Emergency Action Plans...............................................................................1
9/14 Index-3
Electric Power Generation, Transmission, and Distribution

I/J/K, Inspections.....................................................................................51, 52
Recordkeeping
I/J/K, Inspections .........................................................................................52
Electrical
I/J/K, Inspections.....................................................................................55, 56
Safeguards for Personal Protection
I/J/K, Inspections .........................................................................................56
Selection and Use of Work Practices
I/J/K, Inspections .........................................................................................55
Use of Equipment
I/J/K, Inspections .........................................................................................56
Wiring Design and Protection
I/J/K, Inspections .........................................................................................55
Electrical Protective Equipment
I/J/K, Inspections .........................................................................................17
Emergency Response
F/G, First Aid ................................................................................................2
Emergency Stop Buttons
Ergonomics
E, Ergonomics ..............................................................................................1
E-Stops
Exit Routes
E, Exit Routes...............................................................................................1
Exits
E, Exit Routes...............................................................................................1
Explosives and Blasting Agents
I/J/K, Inspections .........................................................................................13
Exposure Control Plan
Index-4 9/14
Exposure Incidents
Extension Cords
E, Extension Cords.........................................................................................1
Eye Protection
E, Eye and Face Protection ..............................................................................1
Eyewashes
F
Face Protection
Fall Protection
A, Aerial Lifts................................................................................................1
F/G, Fall Protection ........................................................................................1
F/G, Fixed Ladders.........................................................................................2
P/Q, Portable Ladders .....................................................................................1
S, Scissor Lifts ..............................................................................................1
Fire Brigades
I/J/K, Inspections .........................................................................................19
F/G, Fire Prevention Plans................................................................................1
First Aid
F/G, First Aid ................................................................................................1
F/G, First Aid Kits...........................................................................................1
First Aid Kits
F/G, First Aid Kits...........................................................................................1
First Aid Supplies
F/G, First Aid ................................................................................................2
F/G, First Aid Kits...........................................................................................3
Fixed Extinguishing Systems
I/J/K, Inspections.....................................................................................20, 21
Recordkeeping
I/J/K, Inspections .........................................................................................21
9/14 Index-5
Fixed Ladders
F/G, Fixed Ladders.........................................................................................1
Flammable Liquids
F/G, Flammable Liquids ...................................................................................1
I/J/K, Inspections..........................................................................................11
Flexible Cords
Flushing Fluid
Forging Machines
I/J/K, Inspections .........................................................................................43
Recordkeeping
I/J/K, Inspections .........................................................................................43
Forklifts
Formaldehyde
I/J/K, Inspections .........................................................................................59
G
Grain Handling
I/J/K, Inspections .........................................................................................55
Grinders
H
Handrails
S, Stairs ......................................................................................................1
Hard Hats
I/J/K, Inspections .........................................................................................17
H, Hazard Communication ................................................................................1
HazCom
HAZWOPER
I/J/K, Inspections .........................................................................................14
Recordkeeping
I/J/K, Inspections .........................................................................................14
Index-6 9/14
Head Protection
I/J/K, Inspections .........................................................................................17
Helicopters
I/J/K, Inspections .........................................................................................40
Hepatitis B
Hepatitis B Vaccination
Hydrogen
I/J/K, Inspections..........................................................................................11
I
Inorganic Arsenic
I/J/K, Inspections .........................................................................................57
Recordkeeping
I/J/K, Inspections .........................................................................................57
Inspection
F/G, First Aid Kits...........................................................................................1
F/G, Fixed Ladders.........................................................................................2
I/J/K, Inspections ...........................................................................................1
P/Q, Portable Fire Extinguishers.........................................................................1
Inspections
R, Recordkeeping ..........................................................................................1
S, Storage Racks...........................................................................................2
Ionizing Radiation
I/J/K, Inspections .........................................................................................59
L
Labeling
Ladders
I/J/K, Inspections ...........................................................................................5
Fixed Ladders
I/J/K, Inspections ...........................................................................................5
9/14 Index-7
Portable Metal Ladders

I/J/K, Inspections ...........................................................................................5
Portable Wood Ladders
I/J/K, Inspections ...........................................................................................5
Laundry
Lifting
E, Ergonomics ..............................................................................................1
Loading Docks
Lockout
L, Lockout/Tagout ..........................................................................................2
Lockout/Tagout
I/J/K, Inspections .........................................................................................18
L, Lockout/Tagout ..........................................................................................1
Reference, OSHA Letters of Interpretation...........................................................46
Recordkeeping
I/J/K, Inspections .........................................................................................18
Locks
L, Lockout/Tagout ..........................................................................................5
Logging
I/J/K, Inspections .........................................................................................48
M
Machine Guarding
Manlifts
I/J/K, Inspections .....................................................................................10, 11
Recordkeeping
I/J/K, Inspections..........................................................................................11
E, Exit Routes...............................................................................................3
F/G, First Aid Kits...........................................................................................2
Index-8 9/14

S, Storage Racks...........................................................................................3
Material Handling
Means of Egress
E, Exit Routes...............................................................................................1
Mechanical Power Presses
I/J/K, Inspections.....................................................................................41, 42
Recordkeeping
I/J/K, Inspections.....................................................................................41, 42
Mechanical Power-Transmission Apparatus
I/J/K, Inspections .........................................................................................43
Medical Treatment
Methylenedianiline
I/J/K, Inspections .........................................................................................59
Minor Servicing
L, Lockout/Tagout ..........................................................................................6
MSDs
E, Ergonomics ..............................................................................................1
Musculoskeletal Disorders
E, Ergonomics ..............................................................................................1
N
Needlesticks
Non-Permit Required Confined Space
P
Paint Booths
S, Spray Booths ............................................................................................1
Parking Lots
Periodic Inspections
L, Lockout/Tagout ..........................................................................................7
9/14 Index-9
Permit-Required Confined Space

Personal Fall Protection Systems
B, Bloodborne Pathogens ...............................................................................10
Platforms
F/G, Fixed Ladders.........................................................................................3
S, Stairs ......................................................................................................1
Portable Containers
H, Hazard Communication ..............................................................................10
I/J/K, Inspections .........................................................................................20
Portable Ladders
Portable Powered Tools
I/J/K, Inspections .........................................................................................43
Power Strips
I/J/K, Inspections .........................................................................................22
Powered Platforms for Building Maintenance
I/J/K, Inspections........................................................................................7, 8
Recordkeeping
I/J/K, Inspections ...........................................................................................8
PPE
Press Brakes
Index-10 9/14
Process Safety Management of Highly Hazardous Chemicals

I/J/K, Inspections.....................................................................................13, 14
Recordkeeping
I/J/K, Inspections .........................................................................................14
Pulp, Paper, and Paperboard Mills
I/J/K, Inspections .........................................................................................45
R
Recordkeeping
I/J/K, Injury and Illness Recordkeeping ............................................................1, 15
L, Lockout/Tagout .........................................................................................10
R, Recordkeeping ..........................................................................................1
Refresher Training
T/U/V, Training ..............................................................................................1
Regulated Waste
Rescue
Respirators
R, Respiratory Protection .................................................................................1
I/J/K, Inspections.....................................................................................15, 16
R, Respiratory Protection .................................................................................1
Recordkeeping
I/J/K, Inspections .........................................................................................16
Restricted Work
Rim Wheels
I/J/K, Inspections .........................................................................................22
Rolling Stock
Roofs
9/14 Index-11
S
Safety Chains
Safety Data Sheets
Safety Data Sheets (MSDS)
R, Recordkeeping ..........................................................................................2
Sawmills
I/J/K, Inspections .........................................................................................47
Scaffolding
I/J/K, Inspections ...........................................................................................6
Scissor Lifts
S, Scissor Lifts ..............................................................................................1
SDS
Seat Belts
Sharps
Sharps Containers
Showers
Slings
I/J/K, Inspections.....................................................................................40, 41
Recordkeeping
I/J/K, Inspections .........................................................................................41
Spill Kit
Spray Booths
S, Spray Booths ............................................................................................1
Spray Finishing
I/J/K, Inspections .........................................................................................12
S, Spray Booths ............................................................................................1
Stairs
S, Stairs ......................................................................................................1
Index-12 9/14
Standpipe and Hose Systems

I/J/K, Inspections .........................................................................................20
Storage Cabinets
F/G, Flammable Liquids ...................................................................................2
Storage Racks
S, Storage Racks...........................................................................................1
Swinging Gates
T
Tagout
L, Lockout/Tagout .........................................................................................12
Telecommunications
I/J/K, Inspections.....................................................................................49, 51
Recordkeeping
I/J/K, Inspections .........................................................................................51
Training
A, AEDs......................................................................................................1
A, Aerial Lifts................................................................................................2
F/G, Fire Prevention Plans................................................................................4
I/J/K, Inspections .........................................................................................60
L, Lockout/Tagout .........................................................................................13
P/Q, Powered Industrial Trucks.........................................................................11
S, Scissor Lifts ..............................................................................................2
T/U/V, Training...........................................................................................1, 2
Training Requirements At-A-Glance
T/U/V, Training ..............................................................................................2
U
Universal Precautions
9/14 Index-13
V
Vehicle-Mounted Elevating and Rotating Work Platforms
I/J/K, Inspections .........................................................................................10
Ventilation
I/J/K, Inspections..........................................................................................11
W
Walking-Working Surfaces
S, Stairs ......................................................................................................1
Walking–Working Surfaces
Welding
I/J/K, Inspections.....................................................................................44, 45
General
I/J/K, Inspections .........................................................................................44
Oxygen-Fuel Gas Welding and Cutting
I/J/K, Inspections .........................................................................................44
Recordkeeping
I/J/K, Inspections .........................................................................................45
Resistance Welding
I/J/K, Inspections .........................................................................................45
Workplace Inspection
I/J/K, Inspections ...........................................................................................1
Index-14 9/14

Workplace Safety Answer Manual Q A J J Keller Associates 2014 PDF

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How to Use This Manual

Still Have a Question?

Must employees be trained to use automated external deﬁbrillators (AEDs)?

Do I need an AED in the workplace?

What is an aerial lift?

Is fall protection required when operating a man lift?

3/13 Aerial Lifts–1

Is separate training required for each type of aerial lift?

2–Aerial Lifts 3/13

Aisles and Walkways

Markings and Labeling

What color must aisles and walkways be marked?

How wide do aisles need to be?

Aisles and Walkways–1

Is there a minimum distance required to be maintained between equipment and

2–Aisles and Walkways

Bloodborne Pathogens .......................................................................... 1

Original content is the copyrighted property of J. J. Keller & Associates, Inc.

Who is covered by the standard?

Are employees such as housekeepers, maintenance workers, and janitors covered

Exposure Control Plan

What is an exposure control plan?

Does the exposure control plan need to be a separate document?

How often must the exposure control plan be reviewed?

Must the exposure control plan be accessible to employees?

What should be included in the evaluation of an exposure incident?

What testing must be done on the source individual?

When is the exposed employee’s blood tested?

What type of information must be provided to the employee(s) following an exposure

Who must be offered the hepatitis B vaccination?

When must the hepatitis B vaccination be offered to employees?

Can pre-screening be required for hepatitis B titer? Post-screening?

Can the employer make up its own declination form?

Can employees refuse the hepatitis B vaccination?

Is a routine booster dose of hepatitis B vaccine required?

Whose responsibility is it to pay for the hepatitis B vaccine?

What does OSHA mean by the term “contaminated laundry?”

How should contaminated laundry be handled?

Markings and Labeling

When are labels required?

What are the required colors for the biohazard label?

Can there be substitutes for the biohazard label?

What are the exceptions to the labeling requirement?

• Individual containers of blood or other potentially infectious materials that are

Personal Protective Equipment

Who is responsible for providing personal protective equipment (PPE)?

When should gloves be changed?

What must be contained in an employee medical record?

Who keeps the medical records?

How long must medical records be kept?

What must be included in a bloodborne pathogen training record?

How long must bloodborne pathogen training records be kept?