Special Topics in Safety Management

If You’ve Got Questions

Today and tomorrow, we present questions about OSHA regulatory requirements on a number of different issues, and the answers from BLR’s safety experts.

Q. Do hand and power tools have annual inspection criteria above and beyond the need to inspect prior to use?
A. There are no OSHA requirements under the hand and power tool rules at 29 CFR 1910.242-244 for annual inspection beyond inspection prior to use. OSHA generally requires employers to follow the manufacturer’s instructions for power tool maintenance and inspection, if any. However, jacks must be inspected every 6 months. Explosive-actuated fastening tools should be inspected at regular intervals and repaired in accordance with the manufacturer’s instructions.

Q. We want to classify which chemicals are carcinogenic, mutagenic, or toxic. Is there an easy way to determine the classification?
A.
Most newer safety data sheets (SDSs) should have the information in Section 2—Hazard Identification and Section 11—Toxicological Information. Also contact the chemical manufacturer listed on the SDS to make sure you have the most current version, and look at the federal Department of Health and Human Service’s National Toxicology Program website, which lists chemicals and their properties in alphabetical order.


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Q. Are there any guidelines to assist companies on determining what is acceptable concerning facial hair and respirators, or is it up to the employer?
A. It’s up top the employer to determine what is acceptable to comply with the respiratory protection rule at 29 CFR 1910.134(g). But OSHA does offer some guidance in a letter of interpretation: "The standard states that the employer cannot permit respirators with tight-fitting facepieces 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. While the standard does not ban beards, per se, it does require employers to ensure that bearded employees who are required to wear tight-fitting facepieces trim their beards so that they do not interfere with the sealing surface of the respirator or are not so large that they could interfere with valve function.

Q. We currently have a trained emergency response technician with basic first aid and CPR certification. Do we also need to train our electrical engineers and maintenance electricians in basic first aid and CPR?
A. OSHA’s 29 CFR 1910.151 applies to all employers in general industry. It requires employers to ensure that there are one or more people in the workplace adequately trained to provide first aid and that first aid supplies are available unless there is a hospital, clinic, or infirmary for treating injured employees in proximity to the workplace (within 3 to 4 minutes for life-threatening emergencies). If you determine you need to provide first aid in-house, ensure that all shifts have at least one person trained in first aid.


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Q. Our company maintains OSHA 300 logs for multiple office locations. Can we create a single companywide OSHA 300 log for the current year and going back several years under the current rules?
A. An employer must keep a separate OSHA 300 log for each establishment run by the company that is expected to be in operation for 1 year or longer. Combining logs is allowed only if all the following conditions are met:

  • The employer operates multiple locations as a single business operation under common management;
  • The locations are all in close proximity to one another; and
  • The employer keeps one set of business records for the locations, such as records on the number of employees, their wages and salaries, sales or receipts, and other kinds of business information.

OSHA gives the following example of close proximity: One manufacturing establishment might include the main plant, a warehouse a few blocks away, and an administrative services building across the street.

Q. How often must our eyewash stations be tested, and does an eyewash station need to be a certain PSI coming out?
A. The OSHA standard for first aid (29 CFR 1910.151) does not set any specifications for emergency eyewash and shower equipment. But OSHA suggests that equipment that complies with the American National Standard for Emergency Eyewash and Shower Equipment consensus standard (ANSI Z358.1) would usually meet the intent of the OSHA rule. You can also read your eyewash station documentation or contact the manufacturer to determine testing requirements and if the equipment meets the guidelines of the ANSI standard.

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