OSHA Compliance Posts
Yes. OSHA's standards at 29 CFR § 1910.212 and 29 CFR § 1910.219 apply to the safeguarding of machines and mechanical power-transmission equipment and require guarding to protect the operator and other employees in the area from hazards such as those created by ingoing nip points, rotating parts, flying chips, and sparks. In regard to the gap dimension between belts and their respective guards, § 1910.219 (e)(1)(i) states:
Please note that the requirements for guarding belts contained in 29 CFR § 1910.219 do NOT apply to the following types of belts when they are operating at two hundred and fifty (250) feet per minute or less: Membership Content
NOTE: I have never managed a facility/workforce where we required Hi-Vis garments, except for Fire Watches and PRCS Entry Attendants, but those requirements were not for the user's safety, so we did not get into all the ANSI requirements for these vests. However, I do equate this Hi-Vis effectiveness concern to what I dealt with regarding Flame Retardant Clothing (FRC) and its continued effectiveness. Just wearing the PPE is NOT all that matters - wearing PPE that will provide the level of protection we expect is KEY to protecting the user. ALL PPE will lose its effectiveness over time, and it is incumbent upon us to establish this time (with a safety margin included) to ensure the PPE can provide the level of protection we intended when specifying the need for said PPE.
I spent last night and this morning assisting with an industrial accident. The facility requires Hi-Vis clothing/vests and specifies they must be TYPE-R ANSI Class 2. I loved that they DEFINED and QUANTIFIED their requirements using an ANSI standard. I looked at the label in my assortment of Hi-Vis PPE and found a vest meeting this requirement. My Safety Helmet is also "Hi-Vis" with reflective stripping, but I got no credit for my HH. For the record, a TYPE-R ANSI Class 2 vest must have at least:
I will use one of the last tests when a facility has hit home runs in managing its Hazardous Communications program. They are great with their container labeling, pipe labeling, training, etc. They even could provide an SDS for all their significant chemicals; however, only a tiny percentage of these facilities can do this...
This is an interesting "press release" from OSHA. Although OSHA has a "policy" not to use audits and inspections performed within the facility to issue citations against, when the employer does NOT address the hazards identified in the inspections and audits, OSHA can take issue with this failure to abate. This is what seems to have happened here. A complaint initiated the inspection. OSHA cited a steel fabrication business after finding the company willfully exposed workers to safety and health hazards at its Millville shop. OSHA issued four willful and seven serious violations and proposed $348,683 in penalties. The agency's investigation began on July 26, 2023, in response to a complaint. "A few months before our inspection, the facility hired a safety consultant who identified multiple safety and health hazards at the Millville fabrication shop. However, the company failed to correct the hazards, which is unacceptable" (OSHA Area Director)
Your letter discusses concerns with the safety of compressed gas cylinders on some types of portable carts configured for “in use” or “connected for use.” Specifically, you mention that cylinders, which are top heavy and therefore can be unstable (unbalanced), are commonly found poorly secured to the cart and leave the cylinders susceptible to toppling over when used, moved, or stored. In your letter, several pictures are provided to illustrate your point (See Pictures 1, 2, and 3) of poorly secured cylinders. Question 1: Are acetylene cylinders positioned at a 45-degree angle from vertical, as shown in picture 4, acceptable to OSHA while in use, moved, or stored? Question 2: Are cylinder carts subject to the special design, and if so, please identify the standard.
CLICK HERE for the LOI (posted recently, but dated 2021)
OSHA answers the following questions as they relate to 1910.178 Powered Industrial Trucks
Scenario: In an OSHA interpretation letter dated June 27, 2011, OSHA noted that “ANSI / National Golf Car Manufacturers Association (NGCMA) Z130.1-2004 defines a golf car as, “a vehicle used to convey a person or persons and equipment to play the game of golf in an area designated as a golf course.” Golf cars are considered by design to be recreational vehicles and are exempt from 29 CFR 1910.178. Again, it is the design of the vehicle that is the determining factor of whether or not it is considered a powered industrial truck, rather than the manner in which it is utilized.
OSHA's short answer is YES; 29 CFR 1910.178 applies to the equipment listed above. Here is their reasoning.
NOTE: some emphasis is by me and some links have been added for ease of access to referenced documents/sources |
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