FAQ: OSHA

Ask an Expert your questions about OSHA.

FAQ: OSHA

Legal Requirements
What is the definitive source for determining law/requirements from optional standards regarding NFPA, NEC and ANSI?
OSHA cites that you shall follow the guidelines of the NFPA 79 and ANSI.
OSHA product reviews
Does OSHA review products for OEMs? We would like their opinions on how to make our machines better, but they seem only interested in HOW we make them HERE.
OSHA does not review products. Products are typically tested by organisations like the UL. OSHA uses the applicatble Machine safety Standards to determine whether that particular application fulfills the safety requirements for machine safety. A risk assessment on your equipment would indicate where if at all your machine is insufficient when it comes to improving safety. The risk assessment is now part of OSHA's requirements for machinery.
Consistent safety standards
Is there a date for harmonized safety standards between US / Canada and Europe?
Safety standards are evolving as we speak, this is due to constant changes in working environments, availabilty of better technologies etc. Since this a continuous process there is no fixed date for harmonisation. But the harmonisation has started, as can be seen in the NFPA 79 which refers to IEC 61508.
Grandfather clause
How do new safety rules (OSHA or NFPA 79) relate to machines built prior to the safety rules relating to that machine going into effect? [The "grandfather" clause]
All machinery is now required to have a risk assessment, plus any changes to the safety equipment on that machine since it was installed would void any grandfather clause.
Basic safety equipment
What basic safety equipment is needed on the job?
The Occupational Safety and Health Administration (OSHA) is charged with helping employers and their workers to operate in a safe workplace. One simple way to ensure plant floor safety is to understand the proper use of personal protective equipment (PPE). Here are some of the items on the OSHA safety checklists for use of PPE in the workplace: Eye and Face Protection - Safety glasses or face shields are worn any time work operations can lead to foreign objects entering the eye such as during welding, cutting, grinding, nailing, or when working with concrete and/or harmful chemicals or when exposed to flying particles. Eye and face protectors are selected based on anticipated hazards. Safety glasses or face shields are worn when exposed to any electrical hazards, including work on energized electrical systems. Hand Protection - Gloves should fit snugly. Workers wear the right gloves for the job (for example, heavy-duty rubber gloves for concrete work, welding gloves for welding, insulated gloves and sleeves when exposed to electrical hazards). Electrical Safety - Work on new and existing energized (hot) electrical circuits is prohibited until all power is shut off and grounds are attached. An effective Lockout/Tagout system is in place. Frayed, damaged or worn electrical cords or cables are promptly replaced. All extension cords have grounding prongs. Protect flexible cords and cables from damage. Sharp corners and projections should be avoided. Use extension cord sets with portable electric tools and appliances that are the three-wire type and designed for hard or extra-hard service. (Look for some of the following letters imprinted on the casing: S, ST, SO, STO.) All electrical tools and equipment are maintained in safe condition and checked regularly for defects and taken out of service if a defect is found. Do not bypass any protective system or device designed to protect employees from contact with electrical energy. All electrical tools must be properly grounded unless they are of the double insulated type.
NFPA 70E
What is NFPA 70E and why should I care?
The National Fire Protection Association sets recognized standards for electrical safety in the workplace. NFPA 70E specifically addresses arc flash hazards, which are dangerous situations that can cause injury, severe burns, and death if a worker is exposed to an electrical arc. NFPA and OSHA have worked together to establish this standard. For more information about this standard, visit: http://www.nfpa.org or http://www.osha.gov
Manufacturing OSHA violations
What are the top OSHA violations in manufacturing?
Here are the top 10, cited by OSHA from October 2006 through September 2007: The control of hazardous energy (lockout/tagout). Failure to meet general requirements for all machines. Wiring methods, components, and equipment for general use. Respiratory protection. Failure to meet general OSHA requirements. Hazard communication. Mechanical power-transmission apparatus. Powered industrial trucks. Guarding floor and wall openings and holes. Abrasive wheel machinery.
OSHA Teaching certifications
What certifications are required to teach OSHA required classes? Example: Confined Space/Hazard Communication
OSHA has training courses that are conducted by themselves or by Authorised thiry party training organisations. For general safety requirements the 40 hour course is required after which the participant can conduct the 10 and 30 hour OSHA authorised courses. More specific training details are available on the OSHA website. Or visit the Siemens site for Safety training classes. (www2.sea.siemens.com\training)
Top ten problems
What are the top 10 problems OSHA looks for in a company.
Here are a few: Don't enforce safety rules, Don't take a systematic approach toward safety, Don't use appropriate engineering controls, Conduct a safety audit, identify a serious hazard and do nothing about it, Fail to control the flow of information during and after an inspection, Don't correct hazards OSHA has cited you for and ignore commonly cited hazards, Keep inaccurate OSHA 300 logs and have disorganized safety files
Machine retrofitter requirements
What are the requirements relating to a machine retrofitter?
Required by OSHA to follow the guidelines of the NFPA 79 and ANSI standards for the application.
OSHA and NFPA standards
MSHA's regulation is somewhat different from OSHA in their regulations, but I understand NFPA 70E is going to start being enforced soon. Briefly, what does compliance to that standard look like with regard to what we have just discussed?
Information Circular 9480 - Programmable Electronic Mining Systems recommendations were developed as a joint project between the National Institute for Occupational Safety (NIOSH) and Health and the Mine Safety and  Health Administration (MSHA) . They are intended for use by mining companies, original equipment manufacturers, and after-market suppliers to these mining companies. Users of these reports are expected to consider the set in total during the design cycle. These best practice recommendations comprise a nine-part series of recommendations and guidance addressing the functional safety of processor-controlled mining equipment. It is part of a risk-based system safety process encompassing hardware, software, humans, and the operating environment for the equipment’s life cycle. It references directly the IEC 61508 standard for PLCs which is the same standard NFPA 79. OSHA mandates the NFPA 79 through incorporation by reference.
OSHA machinery categorizations
When considering machine safety, there is a diverse set of opinions out there regarding machine categories (and therefore what safety regulations apply); how does OSHA categorize machinery, if at all?
OSHA  cites the NFPA 79 and ANSI.
Locking out machinery
Our company policy requires locking out machinery to unjam them.  We use Cat3 circutry.  Isn't this satisfactory according to OSHA?
The actual safety requirements can only be accessed by conducting a Risk Assesment,  which would document what the hazards are and what level/category of safety is required for the application by looking at severity of injury, time of exposure and possibility of avoidance. This analysis then shows, whether the wiring or process followed to achieve the required safety level/category is sufficient of not.

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