Special Topics in Safety Management

Regulatory Q&A: What’s the OSHA Rule Concerning…?

Yesterday, we presented a number of questions about OSHA regulations. Today, we conclude our Q&A session with more questions and more answers.

Q. I have read that the GHS requirements for OSHA’s hazard communication rule do not require in-house chemical containers (those that will never be shipped or leave the workplace) to be labeled with the new GHS container label as long as they meet either the NFPA or the HMIS labeling requirements. Is that true?
A. As an alternative to labeling all individual process containers, employers can use alternative labeling systems such as the NFPA and the HMIS systems, as long as those systems are consistent with the GHS labeling system. For example, NFPA and HMIS hazard statement and pictogram on the label must be consistent with the corresponding hazard statement and pictogram specified in the OSHA rule. If you become aware of any significant new information about the hazards of a chemical, you must revise labels for the chemical within 6 months of becoming aware of the new information.

Q. Is the written instruction (i.e. written LOTO procedure) for lockout/tagout required to be posted and hung at each machine? Or does the regulation allow the written instructions to be filed away for easy access and training on how to access, and can the written procedures be kept online?
A. OSHA’s lockout/tagout rule at 29 CFR 1910.147(c) does not require the written LOTO procedures to be posted on machines. It states that the employer “shall establish a program consisting of energy control procedures, employee training, and periodic inspections,” but the rule does not specify where the written procedures must be kept.

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We suggest you use OSHA’s electrical rule at 1910.333(b)(2), Locking and Tagging section, for guidance. It says, “[T]he employer shall maintain a written copy of the [lockout/tagout] procedures and shall make it available for inspection by employees…” and OSHA inspectors. It is up to you to determine the best way to make LOTO procedures available for inspection by employees. Online access might be part of “making the written instructions available,” but make sure you have a reliable backup system for document access in case the electronic [online] system fails.

Q. Is it required that a forklift operator demonstrate hands-on operation of a forklift every 3 years or is classroom instruction and evaluation sufficient?
A. At least every 3 years, you must conduct an evaluation of each industrial truck operator’s performance. If an operator has been previously trained and has been evaluated at 3 years and found competent to operate the forklift safely, additional training is not required with the triennial evaluation. However, refresher training and evaluation of the effectiveness of training must be provided whenever the employee:

  • Operates the vehicle in an unsafe manner;
  • Has been involved in an accident or near-miss incident;
  • Is assigned to drive a different kind of truck; or
  • There are changes in workplace conditions that could affect safe operation of the forklift.

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