Letter: OSHA standard descriptions need more detail

While it is appreciated that Safety+Health magazine publishes OSHA’s Top 10, and certainly informing employers that this is one area they might consider concentrating on to see where they might fall in regards to any of these applicable standards OSHA has cited, I would like you to please consider the following points of potential miscommunication regarding your MFC charts and the brief explanations of the applicable OSHA standards listed within the “Top 5 sections cited” for each of the Top 10 standards:

• Under No. 4 (Respiratory Protection), 1910.134(c)(1) is stated simply as “respiratory protection requirement” when, in fact, this particular paragraph of the standard reads as follows: “In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer shall establish and implement a written respiratory protection program with worksite-specific procedures.” This may indeed be a “respiratory protection requirement,” although as you can see the main point of this particular paragraph is that, when applicable, an employer SHALL establish and IMPLEMENT a written respiratory protection program.
• Under No. 5 (Lockout/Tagout), 1910.147(c)(4)(i) is simply stated as “general procedures” when, in fact, this is directly referring to the (very important in this particular OSHA-
mandated program) energy control procedures that are supposed to be – in most cases – specific to the particular LOTO-applicable machine, equipment, system. Here is the actual language: “Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.”
• Under No. 6 (Powered Industrial Trucks), 1910.178(l)(1)(i) is simply stated as “safe operation” when, in fact, this paragraph is stated in the regulations as follows: “The employer shall ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (l).” So as can be seen, this emphasis here is the competency of the operator as DEMONSTRATED by the successful completion of the TRAINING and EVALUATION specified in this particular paragraph.

None of this is to scrutinize your efforts – you are offering some valuable services here to employers and employees. This is to ask you to please consider going the extra step and providing more specifics on what a particular OSHA standard REALLY states. Thank you.

(These comments are mine and I do not speak or write this for USF Safety Florida or any other organization or agency.)

Pat Stark, CHST, PCG, PCC
Safety and health consultant
USF Safety Florida, OSHA Consultation
Tampa, FL