So, you just received the word that due to the increase in OSHA activity along with your company’s increase in near misses and recordable injuries, workplace safety and health is getting “top priority” by upper management. That’s great, right?
Well yes, but you also just received an IOC, or “Inner Office Communication” that you being the Human Resource Director will be given the responsibility of administering the newly or reformed workplace safety and health program. In today’s economic atmosphere companies are asking everyone, upper and mid-management personnel to roll up their sleeves and do a little bit more.
Knowing that there aren’t a dozen or so jobs out there in which you can just walk into and the fact that you actually like your job and position, you accept and begin to get down to business.
Where Do You Start?
When it comes to workplace safety and health, unless you just walked out of a cave or been in a coma for the past 40 plus years, OSHA (Occupational Safety and Health Act) comes to mind. OSHA is the Government Agency (United States of America) that enforces all workplace safety and health rules and regulations.
A quick “Google” on your computer takes you to the OSHA web site ( www.osha.gov ) There you will find an overabundance of information dealing with workplace safety and health issues along with the thousands upon thousands of OSHA rules and regulations. A little intimidating I will admit. But, all the information is there. You just now need to set aside the time to read through it, research areas which you believe are applicable to your specific worksite and get down to business.
A Good Cup Of Coffee May Be Needed.
You shut your office door, told the receptionist you don’t want to be bothered for the next few hours and poured yourself a good cup of “joe”. Let’s get down to business. Not to complicate things you begin to look at the OSHA regulations which you bring up by clicking on Regulations / Standards found on the web page. You begin by looking at the somewhat generic ones listed within the General Industry section.
A little note here, the OSHA General Industry Regulations are recorded under the section known as 29 CFR 1910, the CFR standing for Code of Federal Regulations, it may be a good idea to know that.
Very well, let’s continue. Wow, lots of rules.
You will see that the 1910 (General Industry) standards are categorized in Subparts, ranging from Subpart A all the way to Subpart Z. Each Subpart is titled as to its specific application. For example; Subpart A is titled: General and governs or describes the Act itself, how it will be enforced etc.. In studying this format you quickly see that Subpart D governs Walking – Working Surfaces, now we’re getting into the “meat and potatoes” of the Act. You know you and every other workplace has walking – working surfaces.
This Should Be a “Piece of Cake”.
Really now, how hard could it be to ensure that your workplace complies with the OSHA, Subpart D, 29 CFR 1910.21, Walking-Working Surface Rules and Regulations. You click on the section and you are immediately taken to the “Definition” section of this regulation.
You understand that before you begin to look into the specific rules you better make sure you understand how OSHA defines your walking-working surface. Holy “Watch your Step Batman”! You haven’t even begun to get into the specifics and the list of “definitions” looks like this:
"Floor hole", "Floor opening", "Handrail, "Platform", "Runway", "Standard railing", "Standard strength and construction", "Stair railing","Toeboard","Wall hole","Wall opening","Nose, nosing","Open riser", "Railing","Rise", "Riser", "Stairs, stairway", "Tread", "Tread run", "Tread width", "Ladders", "Stepladder", "Single ladder", "Extension ladder", "Sectional ladder", "Trestle ladder", "Extension trestle ladder", "Special-purpose ladder", "Trolley ladder", "Side-rolling ladder", "Wood characteristics", "Wood irregularities", "Cross grain", "Knot", "Pitch and bark pockets", "Shake", "Check", "Wane","Decay", "Compression failure", "Compression wood", "Low density", "Special-purpose ladder", "Fixed ladder", "Individual-rung ladder", "Rail ladder", "Railings", "Pitch", "Fastenings", "Rungs", "Cleats", "Steps", "Cage", "Well", "Ladder safety device", "Grab bars", "Through ladder", "Side-step ladder", "Bearer", "Boatswain's chair", "Brace", "Bricklayers' square scaffold", "Carpenters' bracket scaffold", "Coupler", "Crawling board or chicken ladder", "Double pole or independent pole scaffold", "Float or ship scaffold", "Guardrail", "Heavy duty scaffold", "Horse scaffold", "Interior hung scaffold", "Ladder jack scaffold", "Ledger (stringer)", "Light duty scaffold", "Manually propelled mobile scaffold", "Masons' adjustable multiple-point suspension scaffold","Maximum intended load","Medium duty scaffold", "Mid-rail", "Needle beam scaffold", "Outrigger scaffold", "Putlog", "Roofing bracket", "Runner", "Scaffold", "Single-point adjustable suspension scaffold", "Single pole scaffold", "Stone setters' adjustable multiple-point suspension scaffold", "Tube and coupler scaffold", "Tubular welded frame scaffold", "Two-point suspension scaffold (swinging scaffold)", "Window jack scaffold", "Working load", "Bearer", "Brace", "Climbing ladder", "Coupler", "Design working load", "Equivalent", "Guardrail", "Handrail", "Ladder stand", "Ledger (stringer)", "Mobile scaffold (tower)", "Mobile." "Manually propelled", "Mobile work platform", "Runner", "Scaffold", "Tube and coupler scaffold", "Tubular welded frame scaffold", "Tubular welded sectional folding scaffold", "Work level."
A Second Cup Of “Joe” May Be Needed.
In writing this article I had to pour another cup, and can’t imagine what you are going through in attempting to read and comprehend all of those definitions, but you had better understand them. Each term is going to be referred to somewhere within those OSHA rules and regulations dealing with Walking-Working Surfaces, and hey, we’re only in Subpart D.
What Needs To Be Done Can Also Be A Little Misleading.
So you feel that you picked and chose the definitions or terminology that may apply to your type of business, so let’s get right into the rules. Staying within Subpart D, Walking-Working Surfaces you come across the regulation ( 1910.22(d) "Floor loading protection) that makes reference to posting the rated load capacity sign on floors which will be used for storage, industrial use, well actually anything if you read the standard. Sounds somewhat easy to do, but wait….you note that on the OSHA web page when viewing that specific regulation the 1910.22 (d) is a lighter color blue then some of the other noted standards, which suggest that if you place your cursor on it, it will take you to another page.
You do it and it does. There you see in makes reference to 3 Standard Interpretations. You click, open and begin to read the interpretations. What you find out is although the standard (29 CFR 1910.22 (d)(1)) tells you to post the rated load capacity sign, you really don’t have to post the rated load capacity sign. Now what is it, I do or I don’t.
Well, it’s sort of yes you do, but if you don’t it really isn’t bad unless you don’t know the rated load capacity and you place material or equipment on the floor which is to heavy and you violate the rated capacity for the floor, which by the way you didn’t post therefore you had no idea what it was……understand.
Reason For So Many Religions.
As a private EH & S Consultant (Independent Consultation Services, LLC) I often use the metaphor of religion when attempting to explain the OSHA regulations and why so many interpretations. You see the CFR (Code of Federal Regulations) is like the OSHA Bible. It establishes rules and regulations employers must adhere to as the Bible establishes life’s rules and regulations Christian need to adhere to.
The reason behind the fact that there are so many different religious beliefs and denominations is because each following has interpreted the Bibles writings to mean something different. I have found that since the OSHA regulations are written in a manner often confusing, the need for proper “interpretation” exists. That is why when searching out the OSHA rules going to the OSHA web page (www.osha.gov) is important.
There you will find, as I mentioned above, sections that have “Interpretations” applied to them. It is very important to read those interpretations. I often make that the comment and have found it to be true; more money and time is spent on OSHA compliance based on miss-interpretation, miss-application and over compliance associated with the OSHA rules and regulations.
Make sure you understand the specific OSHA regulation that is applicable to your specific place of business, task or piece of equipment.
If I may suggest, look at the "intent" of the OSHA regulation you feel applies to you and your workplace. Place an effort on meeting that intent. Then go back and see if your action complies with the wording of the rule itself. Good luck.
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