Get Familiar with the General Duty Clause
By law, all employers must comply with the safety regulations of the Occupational Safety and Health Act (OSHA). The sole purpose of the Act is to prevent work-related injuries, illnesses and death.
Every employer, no matter the size, is governed by the General Duty clause, which states that you must:
“Provide a place of employment that is free from recognized hazards that are causing, or are likely to cause, death or serious physical harm to employees.”
There are literally hundreds of safety standards under the Code of Federal Regulations, which cover a variety of workplace hazards, such as electrical hazards, toxic substances, fall hazards, machine hazards, infectious disease, and fire and explosion hazards.
The standards, and their parts, are grouped into four major categories:
- General industry (29 CFR 1910)
- Construction (29 CFR 1926)
- Maritime industry (which includes shipyards, marine terminals and longshoring) (29 CFR 1915-19)
- Agriculture (29 CFR 1928)
While some standards are specific to just one industry, others apply across every industry. Among the standards with similar requirements for all industries are:
- Access to exposure and medical records: This standard ensures right of access to employees, their designated representatives and OSHA to relevant medical records, including those related to an employee’s exposure to toxic substances.
- Personal protective equipment (or PPE): This standard requires you to provide personal equipment to employees to protect them against certain hazards – and to see to it that they are effectively trained on the use of this equipment. Equipment can range from protective helmets to prevent head injuries in construction, to eye protection, hearing protection, hard-toed shoes and special goggles.
- Hazard communication: To better protect workers, OSHA recently revised its HazCom standard, aligning it with the United Nations’ Globally Harmonized System. The new standard, which will be fully effective in 2016, classifies chemicals based on their health and physical hazards, and establishes consistent labels and Safety Data Sheets (SDSs) for all chemicals made in the U.S. and imported from abroad.
Be aware that although OSHA is a federal agency, dozens of states (and U.S. territories) operate their own OSHA-approved safety and health programs. OSHA permits this as long as the state programs are as strict and effective as federal OSHA standards. This means coverage is provided either directly by federal OSHA or a state program.
Access to Employee Exposure and Medical Records
The purpose of section 1910.1020 is to provide employees and their designated representatives proper access to certain exposure and medical records. It is also designed to allow government officials right of access to these records according to OSHA guidelines. Although you must ensure compliance with this section, keep in mind that you can have these activities carried out by the physician or other healthcare personnel in charge of your employee medical records.
What it says:
- Whenever an employee or designated representative requests access to records, you must provide them in a reasonable time, place and manner.
- You must, upon request, provide OSHA representatives access to employee exposure and medical records (and any analyses drawing from these records).
- When an employee is hired, and at least annually thereafter, you must inform them about the location and availability of these records; the person responsible for maintaining and providing access to records; and each employee’s rights of access to these records.
There are a few idiosyncrasies with this standard. If you’re covered, plan to read the entire text (1910.120) at osha.gov.
Legal lingo: What are “exposure records” and “medical records”
Employee exposure records, which must be kept for at least 30 years (with some exceptions), are any records on:
- Environmental (workplace) monitoring or measuring of a toxic substance or harmful physical agent, including personal, area, grab, wipe or other form of sampling, as well as related collection and analytical methodologies, calculations and other background data relevant to interpretation of the results obtained
- Biological monitoring results that directly assess the absorption of a toxic substance or harmful physical agent by bodily systems (e.g., the level of a chemical in the blood, urine, breath, hair, fingernails, etc.) but not including results that assess the biological effect of a substance or agent or assess an employee’s use of alcohol or drugs
- Safety Data Sheets indicating that the material may pose a hazard to human health
- In the absence of the above, a chemical inventory or any other record that reveals where and when the chemical was used and the identity (e.g., chemical, common or trade name) of a toxic substance or harmful physical agent
Employee medical records, which must be kept for at least the length of employment plus 30 years (with some exceptions), are those concerning the health status of an employee that is made by a physician, nurse or other personnel or technician. They include:
- Medical and employment questionnaires or histories (including job description and occupational exposures)
- The results of medical examinations (pre-employment, pre-assignment, periodic or
episodic) and laboratory tests (including chest and other X-ray examinations taken for establishing a base line or detecting occupational illnesses and all biological monitoring not defined as an “employee exposure record”)
- Medical opinions, diagnoses, progress notes and recommendations
- First aid records
- Descriptions of treatments and prescriptions
- Employee medical complaints
Hazard Communication Standard (HCS)
OSHA’s Hazard Communication Standard (HCS) (1910.1200) is based on a simple concept –
that employees have a right to know the hazards of the chemicals they’re exposed to in the workplace.
Specifically, OSHA’s HCS requires that:
- Chemical manufacturers, importers, and distributors classify the hazards of the chemicals they produce, distribute or import, and prepare labels and Safety Data Sheets
(SDSs) to communicate hazard information to their customers.
- All employers with hazardous chemicals in their workplace develop a HCS program to ensure that labels, SDSs and other forms of warnings are provided to exposed employees – and that they’re trained on how to read these items and handle hazardous chemicals.
To better protect workers from hazardous chemicals, OSHA recently revised its HCS, aligning it with the United Nations’ Globally Harmonized System. The new HCS, which is effective in 2016, will benefit workers by reducing confusion about specific chemical hazards in the workplace, requiring safety training and improving the overall understanding of hazards.
OSHA’s new standard will classify chemicals according to their health and physical hazards, and establish consistent labels and 16-section Safety Data Sheets for all chemicals made in the United States and imported from abroad. The revised standard is expected to prevent an estimated 585 injuries and illnesses annually.
Identifying hazardous chemicals in your workplace
The HCS requires you to prepare a list of hazardous chemicals in your workplace as part of your written hazard communication program. The best way to do this is to survey your workplace; purchasing records also may help.
Look around and take the broadest possible view when preparing the list. Sometimes people think of “chemicals” as being only liquids in containers. The HCS covers chemicals in all physical forms – liquids, solids, gases, vapors, fumes, and mists – whether they are “contained” or not.
Identify the chemicals in containers, including pipes, but also think about chemicals generated in the work operations. For example, welding fumes, dusts and exhaust fumes are all sources of chemical exposures. After compiling the list of chemicals, review the latest OSHA regulations to determine if any of the items can be eliminated from the list because they are exempted materials.
Once you have refined your list of hazardous chemicals, the next step is to determine if you have received Safety Data Sheets for all of them. Check your files against the inventory you have just compiled. If any are missing, contact your supplier and request one. It is a good idea to document these requests, either by copy of a letter or a note regarding telephone conversations. If you have SDSs for chemicals that are not on your list, figure out why. Maybe you don’t use the chemical anymore -- or maybe you missed it in your survey.
Bloodborne Pathogens Guidelines
The Bloodborne Pathogens (1910.1030) section applies to occupational exposure to blood or other potentially infectious materials. OSHA defines bloodborne pathogens as “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).” It defines “Other Potentially Infectious Materials” in three ways:
- The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate among them.
- Any unfixed tissue or organ (other than intact skin) from a human (living or dead).
- HIV containing cell or tissue cultures, organ cultures, and HIV or HBV containing culture medium or other solutions; and blood, organs or other tissues from experimental animals infected with HIV or HBV.
If you have employees at risk of occupational exposure, you must establish a written exposure control plan to eliminate or minimize the danger. You must also take precautions to prevent contact with blood or other potentially infectious materials, including engineering protections, work-practice controls and the appropriate personal protective equipment.
Any employees with occupational exposure should participate in a training program at no cost to them and during working hours. Plan to maintain any related training records for at least three years.
Here are the other main points of the standard:
- Immediately or as soon as possible after use, employees must place contaminated, reusable sharps (sharp objects like needles) in appropriate containers until properly reprocessed.
- You must prohibit eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses in work areas where there is a reasonable likelihood of occupational exposure.
- Employees must clean and decontaminate all equipment, and environmental and working surfaces, after contact with blood or other potentially infectious materials.
- You must make the hepatitis B vaccine and vaccination series available to all employees who have occupational exposure, and post-exposure evaluation and follow-up to all employees who have had an exposure incident.
- You must attach warning labels to containers of regulated waste, refrigerators and freezers containing blood or other potentially infectious material, as well as other containers used to store, transport or ship blood or other potentially infectious materials. Red bags or red containers may be substituted for labels.
- You must maintain a sharps injury log to record percutaneous injuries from contaminated sharps. Record and maintain the log in such a way to protect the confidentiality of the injured employee. (Note: The requirement to establish and maintain a sharps injury log applies to any employer who is required to maintain a log of occupational injuries and illnesses.)
Subpart D: Walking-Working Surfaces
It’s very likely this OSHA section applies to your business, as the only exceptions are farms, mines and domestic work in private residences. Here are the highlights:
- Housekeeping (1910.22). You must keep all places of employment, passageways, storerooms and service rooms clean, orderly and in sanitary condition. In addition, the floor of every workroom must be kept clean and dry. If you have wet processes, maintain drainage while providing false floors, platforms, mats or other dry standing places wherever you can. Finally, keep floors, work spaces and passages free of protruding nails, holes or loose boards.
- Aisles and passageways (1910.22). Keep them clear and in good repair, with no obstruction across or in them that could create a hazard. If you use mechanical handling equipment such as forklifts, make sure there is sufficient, safe clearance for aisles, at loading docks, through doorways, and wherever turns or passage must be made. Mark permanent aisles and passageways appropriately, and provide covers and/or guardrails to protect personnel from the hazards of open pits, tanks, vats, ditches, etc.
- Guarding floor and wall openings and holes (1910.23). All floor openings must have guards, such as railings, toeboards and covers, to ensure people don’t fall into them. Floor openings include stairways, trap doors, walkways above work areas, skylights, manholes, pits and ladder ways. There are similar rules for wall openings that drop more than four feet, as well as open-sided walkways, platforms and runways.
- Ladders (1910.25-27). There are numerous regulations regarding ladders -- fixed and portable, wood or metal -- as well as mobile ladder stands. Most ladders for business use adhere to OSHA regulations, but this standard also covers proper care and usage. For example, inspect any ladder that falls over or is involved in an accident. Take it out of use immediately if it is bent or has broken rungs. And when using a ladder, make sure the distance from the wall to the base is at least a quarter of the ladder’s working length.
- Safety requirements for scaffolding (1910.28). Again, OSHA has many specifications for the design and use of scaffolds, including mobile scaffolds. For instance, scaffolds must be able to stay secure at four times the intended load, and you should never place the legs on planks, concrete blocks, etc. And never move them while someone is working on them.
Self-inspection checklist for walkways
- Are aisles and passageways kept clear and properly marked?
- Are wet surfaces covered with nonslip materials?
- Are holes in the floor, sidewalk or other walking surface repaired properly, covered or otherwise made safe?
- Is there safe clearance for walking in aisles where motorized or mechanical handling equipment is operating?
- Are materials or equipment stored so sharp projections will not interfere with the walkway?
- Are spilled materials cleaned up immediately?
- Are changes of direction or elevation readily identifiable?
- Are aisles or walkways that pass near moving or operating machinery, welding operations or similar operations set up to protect employees from potential hazards?
- Is there adequate headroom for the entire length of any aisle or walkway?
- Are standard guardrails provided wherever aisle or walkway surfaces are elevated more than 30 inches above an adjacent floor or the ground?
Self-inspection checklist for floor and wall openings
- Are floor openings guarded by a cover, a guardrail or the equivalent on all sides (except at stairways or ladder entrances)?
- Are toeboards installed around the edges of permanent floor openings where people pass below the opening?
- Are skylight screens able to withstand a load of at least 200 pounds?
- Is the glass in windows, doors or glass walls of sufficient thickness and type to withstand human impact?
- Are grates or similar covers over floor openings -- such as floor drains -- designed to accommodate foot traffic or rolling equipment?
- Are unused portions of service pits and pits not in use either covered or protected by guardrails or the equivalent?
- Do floor or wall openings in fire-resistant construction have doors or covers compatible with the fire rating of the structure, and do they have a self-closing feature when appropriate?
Subpart E: Exit Routes, Emergency Action Plans and Fire Prevention Plans
Highlights of the standard include:
- Exit routes (1910.36-37). The rules are clear and explicit: An exit route must be permanent, and an exit must be separated by fire-resistant materials. An opening into an exit must be protected by a self-closing fire door that remains closed, or automatically closes in an emergency upon the sounding of a fire alarm or employee alarm system. The number of exit routes must be adequate, and there must be at least two — unless the number of employees, the size of the building, its occupancy or the arrangement of the workplace allows employees to evacuate safely during an emergency. (Likewise, you must have more than two exit routes if the number of employees or the arrangement of the workplace requires it.)
- Exit routes must be as far away as practical from each other so that, if one exit route is blocked by fire or smoke, employees can use the second exit route. Each exit must lead directly outside or to a street, walkway, refuge area, public way or open space with access to the outside. Exit doors must be unlocked from the inside. (Exceptions: prisons or mental health facilities, but special rules then apply.)
- Safeguards designed to protect employees during an emergency -- such as sprinkler systems, alarm systems, fire doors and exit lighting -- must be in proper working order at all times. 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 be clearly visible at all times. You must install and maintain an operable employee alarm system that has a distinctive signal to warn employees of fire or other emergencies, unless employees can promptly see or smell a fire or other hazard in time to warn others.
- Emergency action plans (1910.38). You must have an emergency action plan whenever an OSHA standard in this part requires one. An emergency action plan must be in writing, kept in the workplace and available for employee review. However, if you have 10 or fewer employees, you may communicate the plan verbally to employees. You must maintain an employee alarm system (though voice communication is acceptable for workplaces with 10 or fewer employees). Review the emergency action plan with each employee covered by the plan when the plan is developed, or when the employee is first assigned to a job, when the employee’s responsibilities under the plan change and when the plan is changed.
Additionally, you must have a fire prevention plan (1910.39) when an OSHA standard in this part requires one. A fire prevention plan must be in writing, be kept in the workplace and be available for employee review. However, if you have 10 or fewer employees, you may communicate the plan verbally to employees. A fire prevention plan must include:
- 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
- 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
- The name or job title of employees responsible for the control of fuel source hazards
You must inform new employees of the fire hazards they may encounter. You also must review with each employee the parts of the fire prevention plan designed for their self-protection.
Self-inspection checklist for exiting/evacuation
- Are all exits marked with an exit sign and illuminated by a reliable light source?
- Are the directions to exits, when not immediately apparent, marked with visible signs?
- Are doors, passageways or stairways that are neither exits nor access to exits but could be mistaken for exits, appropriately marked (“Not an Exit,” “To Basement,” etc.)?
- Are exit signs labeled with the word “Exit” in lettering at least 5 inches high and the stroke of the lettering at least l/2-inch wide?
- Are exit doors side-hinged?
- Are all exits kept free of obstructions?
- Are there at least two ways to exit elevated platforms, pits or rooms where the absence of a second exit would increase the risk of injury from hot, poisonous, corrosive, suffocating, flammable or explosive substances?
- Are there enough exits for prompt escape in case of emergency?
- Is the number of exits from each floor of a building and the number of exits from the building appropriate for the building occupancy load?
- Where exiting occurs through frameless glass doors, glass exit doors, storm doors, etc., are the doors fully tempered, and do they meet the safety requirements for human impact?
Subpart I: Personal Protective Equipment (PPE)
According to 1910.132, employers must provide personal protective equipment (PPE) whenever employees are exposed to hazards from processes or the work environment, chemical hazards, radiological hazards or mechanical irritants capable of causing injury or impairment. This includes protective equipment for eyes, face, head and extremities; protective clothing; respiratory devices; and protective shields and barriers. You must make sure the equipment is properly used and is kept sanitary and reliable.
If you provide your own protective equipment, you must look after its effectiveness. Finally, you’ll need to train employees in the proper use and care of PPE, and log those training sessions.
Here are the specific requirements:
- Eye and face protection (1910.133). You must ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation. Include side protection when necessary, and make sure eye protection incorporates prescription lenses or fits over such lenses.
- Respiratory protection (1910.134). Try first to use engineering controls (such as exhaust systems) to keep the air clear of harmful dusts, fogs, fumes, mists, gases, smokes, sprays or vapors. When that is not feasible, you may allow employees to use respirators. In any workplace where respirators are needed to protect the health of the employee or whenever respirators are required by the employer, you must establish and implement a written respiratory protection program with work site specific procedures.
- Head protection (1910.135). You must make sure that employees wear protective helmets when working in areas where there is a potential for injury from falling objects. You also must make sure employees wear a protective helmet designed to reduce electrical shock hazard when near exposed electrical conductors that could contact the head.
- Occupational foot protection (1910.136). Employees must wear protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, and where feet are exposed to electrical hazards.
- Electrical protective devices (1910.137). This standard concerns the design, care and use of insulating blankets, matting, covers, line hose, gloves and sleeves made of rubber to protect workers from shock or electrocution.
- Hand protection (1910.138). You must require employees to use appropriate hand protection when employees’ hands are exposed to hazards such as those from skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns and harmful temperature extremes.
Self-inspection checklist for personal protective equipment
- Have you selected appropriate and properly fitted PPE to protect employees from hazards -- and made sure your employees use it?
- Have both the employer and the employees been trained in what PPE is necessary for job tasks, when workers need it, and how to properly wear and adjust it?
- Have you provided protective goggles or face shields where there is any danger of flying particles or corrosive materials?
- Do you require approved safety glasses to be worn at all times in areas where there is a risk of eye injuries, such as punctures, abrasions, contusions or burns?
- Do you provide protective gloves, aprons, shields or other protective items where employees could be cut or where there is a reasonably anticipated exposure to corrosive liquids, chemicals, blood or other potentially infectious materials?
- Do you provide hard hats where danger of falling objects exists?
- Do you periodically inspect hard hats for damage to the shell and suspension system?
- Do you require appropriate foot protection where there is the risk of foot injuries from hot, corrosive or poisonous substances; falling objects; or crushing or penetrating actions?
- Do you provide approved respirators when needed?
- Do you keep all PPE sanitary and ready for use?
- Do you provide protection against the effects of occupational noise when sound levels exceed those of the OSHA Noise Standard?
- Do you have adequate work procedures to clean up spilled hazardous materials? Do you provide appropriate PPE and other equipment?
- Do you have appropriate procedures to dispose of or decontaminate PPE contaminated with, or reasonably anticipated to be contaminated with, blood or other potentially infectious materials?
Subpart J: General Environmental Controls
This section covers sanitation, housekeeping and specific safety situations in the workplace (such as confined spaces and lockout/tagout). It applies to all permanent places of employment.
Sanitation (1910.141) guidelines include the following:
- Cleanliness. You must keep your workplace as clean as possible for the type of work you do. Keep floors dry. If you use wet processes, maintain drainage and provide false floors, platforms, mats or other dry standing places. Otherwise, provide waterproof footgear. In addition, make sure waste receptacles do not leak, and keep the workplace free of vermin (e.g., rodents).
- Clean water. You must provide potable water for drinking, cooking and washing (people, foods, cooking or eating utensils, and so forth). If you have sources of nonpotable water — say, for firefighting — make sure signs inform people that the water is unsafe for drinking or washing.
- Toilets. You must have separate toilet facilities for each sex. The number of facilities for each sex is based on the number of employees of that sex. (Example: One toilet for the first 15 employees of each sex.) You don’t need separate-sex facilities where toilet rooms will be occupied by no more than one person at a time, can be locked from the inside and contain at least one water closet.
Subpart J also covers guidelines for temporary labor camps (1910.142) (including requirements on drainage, size, toilet facilities, shelters and cooking, among other things, in temporary labor camps) and signs (1910.144-145) (for example, the color and design of safety signs and tags -- although most companies you buy signs from will already know these rules.)
The section on permit-required confined spaces (1910.146) concerns protecting employees from the hazards of entering permit-required confined spaces. (This section does not apply to agriculture, to construction or to shipyard employment.) A confined space:
- Is large enough to allow an employee to enter and perform assigned work
- Has limited or restricted means for entry or exit. Examples: tanks, vessels, silos, storage bins, hoppers, vaults and pits
- Is not designed for continuous employee occupancy
If your workplace contains permit-required confined spaces, you must inform employees by posting danger signs or other equally effective warnings. If you don’t want employees to enter confined spaces, block them off. If employees need to enter confined spaces occasionally, you’ll need a written permit space program. This program outlines how you will prevent unauthorized entry, identify hazards, and develop and implement the means, procedures and practices necessary for entering and working in confined spaces safely. There are some exceptions, so be sure to read the entire standard if you have confined spaces on the premises.
Finally, Subpart J also has standards on the control of hazardous energy (lockout/tagout) (1910.147). This standard concerns how to protect workers where during the servicing and maintenance of machines and equipment, an unexpected startup, or the release of stored energy could cause injury. (The standard does not cover the construction, agriculture or maritime industries; electrical utilities; or oil and gas well drilling and servicing.) Covered employers must establish a program to disable machines or equipment to prevent injuries during maintenance. Besides energy control procedures, programs must cover employee training and periodic inspections.
What is lockout/tagout? When machinery is idle or being serviced, an accidental startup or release of energy can cause serious harm to employees. Lockout and tagout devices on equipment can prevent these accidents. Equipment cannot be operated until a lockout device is removed, and a tagout device indicates that the equipment may not be operated until the tagout device is removed.
Self-inspection checklist for general work environment
- Are all work sites clean, sanitary and orderly?
- Are all spilled hazardous materials or liquids, including blood and other potentially infectious materials, cleaned up immediately and according to proper procedures?
- Is combustible scrap, debris and waste stored safely and promptly removed from the work site?
- Is all regulated waste discarded according to federal, state and local regulations?
- Is combustible dust cleaned up with a vacuum system to prevent suspension of dust particles in the environment?
- Are covered metal waste cans used for oily or paint-soaked waste?
- Are all oil- and gas-fired devices equipped with flame failure controls to prevent flow of fuel if pilots or main burners are not working?
- Are paint spray booths, dip tanks, etc., cleaned regularly?
- Are the minimum number of toilets and washing facilities provided and kept clean and sanitary?
- Are all work areas adequately illuminated?
- Are employees instructed in proper first aid and other emergency procedures?
Self-inspection checklist for confined spaces
- Are confined spaces thoroughly emptied of any corrosive or hazardous substances, such as acids or caustics, before entry?
- Are all lines to a confined space, which contain inert, toxic, flammable or corrosive materials, valved off and blanked or disconnected and separated before entry?
- Are all impellers, agitators or other moving parts and equipment inside confined spaces locked out if they present a hazard?
- Is either natural or mechanical ventilation provided before confined space entry?
- Are appropriate atmospheric tests performed to check for oxygen deficiency, toxic substances and explosive concentrations in the confined space before entry?
- Is the atmosphere inside the confined space frequently tested or continuously monitored during work?
- Is there a trained and equipped standby employee positioned outside the confined space, whose sole responsibility is to watch the work in progress, sound an alarm if necessary and provide assistance?
- Are employees prohibited from entering the confined space without lifelines and respiratory equipment if there is any question as to the cause of an emergency?
- Is approved respiratory equipment required if the atmosphere inside the confined space cannot be made acceptable?
- Before gas welding or burning is started in a confined space, are hoses checked for leaks, torches lighted only outside the confined area and the confined area tested for an explosive atmosphere each time before a lighted torch is taken into the confined space?
- Is each confined space checked for decaying vegetation or animal matter that may produce methane?
- Is the confined space checked for possible industrial waste that could contain toxic properties?
- If the confined space is below ground and near areas where motor vehicles will be operating, is it possible for vehicle exhaust or carbon monoxide to enter the space?
Self-inspection checklist for lockout/tagout
- Is all machinery or equipment capable of movement required to be de-energized or disengaged and blocked or locked out during cleaning, servicing, adjusting, or setting up operations?
- If the power disconnect for equipment does not also disconnect the electrical control circuit, are the appropriate electrical enclosures identified, and is there a way to disconnect and lock out the control circuit?
- Is the locking out of control circuits, instead of locking out main power disconnects, prohibited?
- Is there a way to lock out all equipment control valve handles?
- Does the lockout procedure require that stored energy (mechanical, hydraulic, air, etc.) be released or blocked before equipment is locked out for repairs?
- Are appropriate employees provided with individually keyed personal safety locks?
- Is it required that only the employee exposed to the hazard can place or remove the safety lock?
- Is it required that employees check the safety of the lockout by attempting a startup after making sure no one is exposed?
- Are employees instructed to always push the control circuit stop button before to re-energizing the main power switch?
- Is there a way to identify employees who are working on locked-out equipment by their locks or accompanying tags?
- Do you have enough accident prevention signs or tags and safety padlocks for any reasonably foreseeable repair emergency?
- If equipment or lines cannot be shut down, locked out and tagged, is a safe job procedure established and strictly followed?
Subpart K: Medical Services and First Aid
This standard is fairly simple, and it applies to all businesses.
- Medical services and first aid (1910.151). You must make medical personnel available for advice and consultation on matters of plant health. If you don’t have an infirmary, clinic or hospital near the workplace, you must train one or more people to administer first aid and have first aid supplies on hand.
Self-inspection checklist for medical services and first aid
- Is there a hospital, clinic or infirmary for medical care near your workplace, or is at least one employee on each shift currently qualified to administer first aid?
- Have all employees who are expected to respond to medical emergencies as part of their job responsibilities received first aid training, including training on how to protect themselves from bloodborne pathogens?
- Have you posted emergency phone numbers?
- Are first aid kits easily accessible in each work area, periodically inspected and replenished as needed?
- Is there an eye-wash station or sink available for quick drenching or flushing of the eyes and body wherever corrosive liquids or materials are handled?
Subpart L: Fire Protection
This section contains requirements for fire brigades and all portable and fixed fire suppression equipment, fire detection systems, and fire or employee alarm systems. It applies to all workplaces except for those in the maritime, construction and agricultural industries.
- Fire brigades (1910.156). Employers do not have to organize fire brigades — defined as an organized group of employees who are knowledgeable, trained and skilled in at least basic firefighting operations — to fight workplace fires. However, if they do, they must follow the safety rules and procedures outlined in this section. It covers organization, training, protective clothing and respiratory protection.
- Portable fire extinguishers (1910.157). This section applies to the placement, use, maintenance and testing of portable fire extinguishers. In general, you must provide portable fire extinguishers and mount, locate and identify them so they are readily accessible to employees. (Standpipe systems are an acceptable alternative for some kinds of fires.) Keep extinguishers charged, operable and in their designated places at all times. This means regular testing. What’s more, you must train employees in the effective use of extinguishers. Note: If you don’t have fire extinguishers and you have chosen to evacuate all employees from the workplace in fire emergencies, this standard does not apply to you. If extinguishers are not for employee use and employees will evacuate, most of this standard will not apply. But, in either case, you’ll need both an emergency action plan and a fire prevention plan. If some employees will evacuate during a fire emergency while other use extinguishers, you must have an emergency action plan.
- Standpipe and hose systems and automatic sprinkler systems (1910.158 and 1910.159). The standpipe standard applies to all small hose, Class II and Class III standpipe systems installed to meet the requirements of a particular OSHA standard. The sprinkler standard applies to all automatic sprinkler systems installed to meet a particular OSHA standard.
- Fire extinguishing systems (1910.160–163). These standards cover dry chemical, gaseous agent, and water spray and foam extinguishing systems.
- Fire detection systems (1910.164). This section applies to all automatic fire detection systems installed to meet the requirements of a particular OSHA standard.
- Employee alarm systems (1910.165). You’ll need an alarm system to alert employees of fires and other emergencies. In small workplaces — one with 10 or fewer employees — you can alert people verbally (shouting). In addition, alarms don’t always need to be loud bells or tones. For example, visual, tactile or audible alarm signals are acceptable. If you have employees with hearing impairments, for instance, flashing lights or vibrating devices can be used.
Self-inspection checklist for fire protection
- Is your local fire department familiar with your facility, its location and specific hazards?
- If you have a fire alarm system, is it certified as required and tested annually?
- If you have outside private fire hydrants, are they flushed at least once a year and on a routine preventive maintenance schedule?
- Are fire doors and shutters in good operating condition?
- Are fire doors and shutters unobstructed and protected against obstructions, including their counterweights?
- Are automatic sprinkler system water control valves, air and water pressure checked periodically as required?
- Is the maintenance of automatic sprinkler systems assigned to responsible persons or to a sprinkler contractor?
- Are sprinkler heads protected by metal guards if exposed to potential physical damage?
- Is proper clearance maintained below sprinkler heads?
- Do you have an adequate number and type of portable fire extinguishers mounted in readily accessible locations?
- Are fire extinguishers recharged regularly and noted on the inspection tag?
- Are employees periodically instructed in the use of fire extinguishers and fire protection procedures?