It is important to know that this is not the only point of consideration when determining if a lockout tagout procedure is required. OSHA has eight requirements that ALL must be met for a lockout tagout procedure exemption to apply.
According to ANSI 92.24-2018, Scissor Lift trainers must be:
experienced with the particular classification of MEWP and knowledgeable regarding the laws, regulations, safe use practices, manufacturers requirements, and recognition and avoidance of hazards associated with MEWPS.
Scissor lift trainers must also be "qualified", which ANSI defines as:
A person, who, by possession of recognized degree, certificate or professional standing, or by extensive knowledge, training and experience, has successfully demonstrated his / her ability to solve or resolve problems to the subject matter, the work, or the project.
OSHA does not list any specific requirements or qualifications for aerial lift trainers. When it comes to the execution of aerial lift training, OSHA defers to the American National Standards Institute, which details these requirements in A92.24-2018 - Training Requirements For The Use, Operation, Inspection, Testing And Maintenance Of Mobile Elevating Work Platforms.
In this regulation, ANSI states:
"All training shall be delivered by a qualified person who is experienced with the particular classification of MEWP and knowledgeable regarding the laws, regulations, safe use practices, manufacturers requirements, and recognition and avoidance of hazards associated with MEWPS."
ANSI defines qualified as:
Aerial Lift trainers must be both qualified and experienced on the MEWP they will be certifying employees on.]]>"A person, who, by possession of recognized degree, certificate or professional standing, or by extensive knowledge, training and experience, has successfully demonstrated his / her ability to solve or resolve problems to the subject matter, the work, or the project.”
OSHA requires respirator refresher training:
The Center For Disease Control is now recommending face coverings for anyone going out in public.
Center For Disease Control Steps To Prevent Illness
Check out XO Safety Academy's Coronavirus Safety For Employees Online Course
]]>One side is blue and says "Affordable Safety Training" the other side has a picture of a Forklift in a warehouse. On that side there is a little section that looks like a computer chip, you can push that part out and put it into your USB port and upload the program that you purchased. If you have any problems uploading the program, please contact us for further instructions.
]]>
If you look at the OSHA references, it is clear that OSHA does not consider a scissor lift an aerial lift. 29 CFR 1926.453 - Aerial Lifts considers scissor lifts to be one of the following:
Scissor lifts do not fit under this classification, so they are not aerial lifts. In 2000, OSHA released a letter of interpretation helpfully titled "Scissor lifts are not aerial lifts - are considered scaffolds."
However, OSHA references an ANSI standard from 1969 for definitions of Aerial Lifts. That standard was updated in 2018 - and it clearly includes scissor lifts as a Group A mobile elevated work platform.
OSHA has not updated their references to match the new ANSI definitions of Mobile Elevated Work Platforms. It seems clear this will eventually happen, as the ANSI regulations are incorporated by reference in the OSHA regulations.
]]>Sometimes, we have our vendors ship the product directly from their warehouse. They still will usually ship within the 24 hour period, but are sometimes sent via UPS, and can take up to 7 days to arrive.
We do our very best to keep you informed of when the product ships and any tracking numbers that we have. If you have a question regarding our shipping policy, please contact us at sales@xosafety.com or call 888-213-0432.
]]>
Employees are required to be fit tested on the exact type, size and model of the respirator they will be using:
If there are changes in an employees body that affect the respirator fit, a new fit test may be required. These changes may include:
Check out XO Safety Academy's Performing Respirator Fit Tests Online Course
29 CFR 1910.134 - Respiratory Protection
OSHA Accepted Fit Test Protocols
]]>
1910.1053(j)(2) requires that silica regulated areas be marked with a sign that reads:
DANGER
RESPIRABLE CRYSTALLINE SILICA
MAY CAUSE CANCER
CAUSES DAMAGE TO LUNGS
WEAR RESPIRATORY PROTECTION IN
THIS AREA
AUTHORIZED PERSONNEL ONLY
You can find the respirable crystalline silica danger sign here.
Silica construction regulations have no specific requirements for signs. 1926.1153(g)(1)(iv) does require the employer to include the method for restricting access to silica hazard areas as part of the exposure control plan. This would include signs or markings of some sort, but the method of communication is up to the employer.
]]>
When operating an aerial lift, the employee must be tied-off to a designated anchor point. This can be accomplished with a body belt or harness. This system is for fall prevention only.
If, for some reason, it is impossible to eliminate the risk of a fall with fall prevention, then a fall arrest system must be used. In this case, it requires:
A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift.
Note to paragraph (b)(2)(v): As of January 1, 1998, subpart M of this part (1926.502(d)) provides that body belts are not acceptable as part of a personal fall arrest system. The use of a body belt in a tethering system or in a restraint system is acceptable and is regulated under 1926.502(e).
Aerial lifts/ boom-type platforms
Section 1926.453(b)(2)(v) of the Aerial Lift standard provides that workers in aerial lifts and boom-type platforms must be tied-off.
For most training subjects, the Trainer just needs to meet certain experience requirements, and be designated by the employer.
All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence. - 1910.178(l)2(iii)
Notice there is no mention of a "Train The Trainer" certification.
The employer shall assure that each employee has been trained, as necessary, by a competent person qualified in the following areas: 1926.503(a)(2)
In this case, OSHA just says the trainer must be "competent".
"Train The Trainer" courses and certifications can be a useful tool for teaching an employee to be a trainer, but they are not official designations, and therefore their is no "expiration date" as it relates to OSHA requirements.
]]>
Secondary chemical containers are the chemical containers most often found in the workplace. While chemical shipping containers must have the full GHS label, OSHA provides employers with a lot of flexibility to create their own secondary container labeling systems.
OSHA requires secondary container labels to have the full GHS label, or:
"Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical."
As you can see from the regulation, the only specific requirement is that that label include the product identifier. The rest of the necessary information can be determined by the employer. You should be sure that the information your company chooses to use be put in writing in the hazard communication program, and that it is consistent on every chemical container.
]]>OSHA considers a space to be confined if it meets all of the following criteria:
A confined space requires a permit for entry if the space has any of the following:
You can use the OSHA Confine Space Adviser to help determine the type of confined spaces at your facility.
29 CFR 1910.134 requires employers to provide "effective" training to employees who are required to use respirators. This training must be completed before the worker uses a respirator, and must reoccur at least annually.
The regulation does not list any specific requirements for trainer qualifications. It just says that it must be "effective", and provided in a manner that is understandable to the employee. It is always good practice to designate someone who has knowledge, training, and experience on the hazards of the workplace and respirator use. It's also a good idea to make your designation in writing.
Video: Respiratory Protection Training Requirements
The Youth Employment section of the Fair Labor Standards Act (29 CFR 570) requires that forklift operators be at least 18 years old.
It is also important to remember that operators 18 and older still need to be trained and certified by their employer.
The OSHA Respiratory Protection Standard 1910.134 requires employers to "identify and evaluate the respiratory hazard(s) in the workplace". While it does require the employer to perform an evaluation, it does not require a specific method, other than it being a "reasonable estimate" of employee exposure. The employer needs to decide the best way to assess employee exposure levels. There are many options available to employers. When selecting a method, it is important that you document everything in writing.
The most accurate way to determine exposure is to perform personal monitoring. This involves the use of badges, air collection pumps, and other devices to track the level of exposure in a work area. While this is the best method, it may be beyond the capabilities or resources of smaller employers. Fortunately, OSHA does permit other options.
Note: Some regulations, like asbestos, require personal monitoring for determining exposure levels.
The employer can monitor fixed locations, or collect samples for short time periods. If this method is used, the employer should perform samples under the worst-case exposure scenarios, to make sure that the assigned level of protection is adequate for all conditions.
There may be data available from product manufacturers, trade associations, or other organizations that document expected exposure levels. If this data is used, the conditions in the workplace must match the conditions in the survey.
Employers with dangerous hazard profiles should consider bringing in a safety and health professional to determine exposure levels. OSHA consultation programs may also be able to help employers determine exposure levels.
If the employer cannot make a reasonable estimate of exposure levels, they must assume that the atmosphere is immediately dangerous to life and health (IDLH), and provide the requisite protection.
A written lockout tagout procedure, otherwise known as an energy control procedure, is required for all activities covered by 29 CFR 1910.147 "The Control of Hazardous Energy" standard. There is an exemption for this rule, provided that the conditions meet all eight of the specified exemptions.
1910.147(c)(4)(i) describes the exemption requirements. A energy control procedure is not required if all of the following conditions exist:
1926.20(b)(1) requires employees to initiate and maintain an accident prevention program that facilitates compliance with regulations. It does not specifically say that the program has to be written, but it is much more difficult to prove the existence of a satisfactory program if you don't have it on paper.
The competent person is an important role for maintaining safety on a construction site. 1926.20(b)(2) requires a system for frequent and regular inspections, by a competent person, to make sure the job site, materials, and equipment are safe and in good working order.
Everything used on a construction site must be compliant with safety regulations. If it is not compliant, it may not be used. 1926.20(b)(3) requires the employer to remove them from service with any of the following means:
1926.20(b)(4) mandates that only employees with proper training or experience may operate equipment or machinery. This training requirement is one of the most overlooked rules in construction. The training and / or experience should be documented for every employee.
Construction Safety and Health Program
29 CFR 1926.20 - General Safety and Health Regulations for Construction
]]>Qualitative fit tests are easier, less expensive, and less accurate. Quantitative fit tests are more accurate, but require special equipment.
The required protection factor is the amount of protection required for employees to be below the permissible exposure level (PEL). For instance, if the PEL for a airborne contaminant is 10 ppm, and the atmospheric contamination level is 200 ppm, then the required protection factor is 20 or greater.
Qualitative fit tests may only be used on negative pressure respirators when the required protection factor is 10 or lower, and the atmosphere is not IDLH.
Quantitative fit tests are required for negative pressure respirators when the required protection factor is greater than 10, or the atmosphere is immediately dangerous to life and health.
The fall hazards in the work area.
How to erect, maintain, inspect, and disassemble the fall protection systems used.
The use and operation of the fall protection systems to be used.
The role of each employee in a safety monitoring system.
The limitations of mechanical equipment while work is performed on low sloped roofs.
The correct procedures for handling and storage of equipment and materials and erection of overhead protection.
The role of employees in fall protection plans.
The OSHA regulations.
The employer can designate a competent person to be the trainer, but the person designated must meet this criteria. It is important that this designation is done in writing, so that it can be presented to OSHA if they ask for it.
OSHA 29 CFR 1926.503 - Fall Protection Training Requirements
]]>29 CFR 1910.146 mentions the training requirements clearly:
1910.146(g)1
"The employer shall provide training so that all employees whose work is regulated by this section acquire the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under this section."
The regulation also mentions that the employer must certify the training has been accomplished.
1910.146(g)(4)
"The employer shall certify that the training required by paragraphs (g)(1) through (g)(3) of this section has been accomplished. The certification shall contain each employee's name, the signatures or initials of the trainers, and the dates of training. The certification shall be available for inspection by employees and their authorized representatives."
It is still important to designate a trainer who has the knowledge, training, and experience to certify confined space workers. It is up to the employer to determine if the training provided was sufficient.
]]>"All operator training and evaluation shall by conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence."
Check out XO Safety Academy's Online Forklift Train The Trainer Course.
The employer can decide, on their own, who meets this definition. We highly recommend this designation is made in writing. The employer should be careful to consider the three requirements of knowledge, training and experience.
Forklift trainers need to have an understanding of safe operation of powered industrial trucks, the hazards in the workplace, and the regulatory requirements. Many experienced operators have a strong understanding of the first two, but need a refresher on the knowledge portion. This is where an online forklift safety training course can be handy.
While it does not mention a specific certification or type of training, the regulation does require that forklift trainers be trained themselves. This could be a previous school, training from a previous employer, or training from a current employer. The training should be listed in your documentation.
The forklift trainer should have experience operating the forklifts in the specific work environment that he will be training in. If you send an employee off to a forklift school to become a trainer, OSHA is likely to frown upon that unless that person has actual experience operating in the workplace.
29 CFR 1926 Subpart L has what's known as vertical fall protection requirements. This standard overrides the general requirement from Fall Protection Subpart M which requires fall protection at six feet above a lower level. Scaffold general requirements 1926.451(g)(1) requires all scaffold workers to have fall protection when working 10 feet or greater above a lower level.
The commonly used supported scaffolding requires either a personal fall arrest system or a guardrail system. Most types of suspended scaffolding will require a personal fall arrest system. Here is chart for fall protection requirements on scaffolds.
Type of Scaffold | Required Fall Protection |
Supported scaffold | Personal fall arrest system or guardrail |
Aerial lift | Personal fall arrest system |
Boatswain's chair | Personal fall arrest system |
Float scaffold | Personal fall arrest system |
Ladder jack scaffold | Personal fall arrest system |
Needle beam scaffold | Personal fall arrest system |
Self-contained scaffold | Personal fall arrest system & guardrail system |
Single-point suspension scaffolds | Personal fall arrest system & guardrail system |
Two-point suspension scaffold | Personal fall arrest system & guardrail system |
Catenary scaffold | Personal fall arrest system |
Crawling board scaffold | Personal fall arrest system or guardrail system |
All other scaffolds | Personal fall arrest system or guardrail system |
For a scaffolding safety training program that includes a written safety plan and forms, check out the Scaffolding Safety Training Compliance Kit.
]]>The employer can designate someone to train employees on the safe use of scaffolding in their work area. OSHA 29 CFR 1926.454 says that:
"The employer shall have each employee who performs work on a scaffold trained by a person qualified in the subject matter to recognize the hazards associated with the type of scaffolding being used and to understand the procedures to control or minimize these hazards."
So employees who perform work on scaffolds must be trained by someone qualified in the subject matter. While this is a bit subjective, OSHA defines a "qualified person" as:
"One who, by possession of a recognized degree, certificate, or professional standing, or by extensive knowledge, training, and experience, has successfully demonstrated his/her ability to solve or resolve problems related to the subject matter, the work, or the project"
If you have an employee who meets the above criteria, based on your evaluation, you can designate them to train employees to use scaffolding.
Any employees who are involved in erection, removal, moving, operating, repairing, maintaining or inspecting must be trained by a competent person, according to 1926.454(b). OSHA defines a competent person as:
"Capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them."
So if you have an employee that meets that definition, they can train other employees on this operation.
Scaffold workers do not need any type of documented certification, although training documentation is always good practice. The compliance directorate for Subpart L says that:
"Section 1926.454 does not require certification, or other documentation, of training. Compliance officers shall evaluate compliance with the training requirements through observation of work practices, inspections of rigging, correct utilization of scaffold equipment, and interviews with employees and management representatives."
Looking for a scaffolding training solution? Check out the Scaffolding Safety Compliance Kit for everything you need. It includes training materials, a scaffolding safety program, and forms. It also comes with a 30 day money back guarantee.
]]>Employees are required to have a respirator fit tested prior to being allowed to use that make and model in the workplace. But who can perform this fit test? Do they require any specific training? Let's take a look at the OSHA regulations.
29 CFR 1910.134 says that:
"The employer shall establish a record of the qualitative or quantitative fit tests administered to an employee, including"
Appendix A Part 1 of the standard says:
"The employer shall conduct fit testing using the following procedures."
So the regulations do not specifically state the requirements for the person performing the fit test, but they do list the specific procedures that must be adhered to.
OSHA does not list specific training requirements for fit test providers. As long as the person you select to perform the fit test can follow the procedure properly and documents the results, you should be compliant. It would be wise to make sure the person you designate to perform the fit tests is familiar with the company respiratory protection program.
Most fit test kits will come with step by step instructions. Use the instructions to practice a few fit tests before completing the real evaluations.
Here is a great free video on respiratory protection and respirator fit testing.
Construction work means work for construction, alteration, and/or repair, including painting and decorating.
Many of the activites occur on a regular basis in workplaces outside of construction sites, but will be covered by the construction standard.
OSHA further clarifies (if you want to call it that) its position on construction with it's explanation of the replacement of a utility pole.
Construction work is not limited to new construction, but can include the repair of existing facilities or the replacement of structures and their components. For example, the replacement of one utility pole with a new, identical pole would be maintenance; however, if it were replaced with an improved pole or equipment, it would be considered construction.
The scope of work also has a lot to do with the classification of construction.
In addition to the concept of one-for-one replacement versus improvement, the scale and complexity of the project are relevant. This takes into consideration concepts such as the amount of time and material required to complete the job. For example, if a steel beam in a building had deteriorated and was to be replaced by a new, but identical beam, the project would be considered a construction repair rather than maintenance because of the replacement project's scale and complexity. Also, if a bridge was to be stripped and re-painted, that would be considered construction work even if the repainting were done on a scheduled basis. Replacement of a section of limestone cladding on a building, though not necessarily a large project in terms of scale, would typically be considered construction because it is a complex task in view of the steps involved and tools and equipment needed to do the work.
OSHA classification of construction reaches far beyond the construction site. Take a close look at your work, and see if it may be classified as construction.
Adoption and Extension of Established Federal Standard - Construction Work
]]>Here is what OSHA says about rescue of workers:
1926.502(d)(20) - The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.
OSHA is not very specific about rescue requirements, other than to say that rescue must be available. Let's take a closer look at these requirements.
While OSHA does not list specific requirements for written rescue plans, ANSI Standard 92.22-2018 does require written rescue plans for mobile elevated lift operators using Group B devices. You can learn more about that on our MEWP Rescue Plan page.
The first option of rescue is that it is provided to employees. This is usually accomplished by calling for emergency services. There are some important things to consider when using this is an option.
The employer may use employees to provide rescue. These employees must be familiar with the correct use of fall protection, as well as proper rescue techniques. Sometimes rescue is as simple as using a ladder to reach fallen workers, other times it is more complicated. Here are some things to consider when relying on employees for rescue:
Watch wind turbine technicians practice rescue from heights.
The OSHA standard does not require written rescue plans or rescue briefings, but they are both an excellent practice. You should make sure that every employee who works at heights knows how to use fall protection, and what rescue method will be used in the event of a fall.
Questions? Comments? Let us know below.
]]>
Employers frequently ask the question "Where can I get my employees certified to operate aerial lifts?" While aerial lift operators do have to be trained and evaluated by the employer, they do not need to be "certified" or "qualified" by any particular organization.
29 CFR 1926.453(b)(2)(ii) says that "Only authorized persons shall operate an aerial lift." The employer has the ability and responsibility to train and authorize operators themselves. While the OSHA standard does not mention specific training criteria, ANSI does have aerial lift training guidelines that OSHA will use to assist them in evaluating if a company aerial lift training program is sufficient.
OSHA explains this requirement in more detail in a standard interpretation in response to a safety managers query:
"In the situation where operator capabilities are the issue, OSHA would first determine if the operator was trained and if no training was provided, issue a citation for violating 1926.21(b)(2). IF training was provided, OSHA would need to use the general duty requirements of paragraph 5(a)(1) of the OSH Act to address any related violations. In so doing, OSHA would use the ANSI requirements to help establish what the industry practice is in regard to operator qualifications. Although OSHA defines the term, "qualified" at 1926.32(1), the terms "certified" and "qualified" would have to be defined by ANSI in this case because it would be that organization's definitions of its own terms that would govern the application of its requirements. Consequently, it is that organization that must define the terms for you."
Employers do not need to get their aerial lift operators certified by an outside body, they just need to be trained and evaluated by the employer.
]]>
Trainers do not need to be trained or certified by any outside body. The employer has the authority to designate an employee to be the trainer. The employer should refer to the specific standard they will be training on for any specific trainer requirements. The Forklift Train the Trainer Page will give you step-by-step guidance for certifying operators in house.
While the employer does have the authority to designate trainers, they should make sure the trainers are experienced in the work area, and understand the policies and procedures required to work safely. Do not designate junior or inexperienced employees.
While it is not specifically required in all cases, it is a good idea to document qualified trainers in writing. This will give you important evidence of your training program should you ever get an OSHA inspection. It should include the name of the person, as well as the reasoning behind the designation. Here is a sample trainer designation form.
]]>