Issue link: http://palletcentral.uberflip.com/i/612297
palletcentral.com PalletCentral • November-December 2015 23 must have qualitative or quantitative fit testing, and have training on the use, maintenance, cleaning and storage of their respirators. For disposable respirators, they must be trained as well (including the need to throw them away after use). If dust masks will be used on a voluntary basis, then Appendix D to 1910.134 must be posted in the "employee notices" area of the workplace. Lockout/tagout requirements also made the OSHA hit parade, and pallet companies and other manufacturers are often cited for not having proper locks and tags, group lockout devices (when more than one employee is working to repair or maintain a single piece of equipment), or for not having specific written procedures on how each machine must be de-energized. Don't forget to include control of hydraulic and pneumatic hazards in addition to electrical shut off requirements when drafting the procedures. The employer must also annually observe a representative number of workers actually perform lockout/tagout and document this, in order to comply with the rule. This standard is also a key enforcement tool in OSHA's National Emphasis Program (NEP) on amputations, and the pallet sector is included in that initiative. Another "Top 10" standard covered under the amputation NEP is machine guarding. The industry has had a checkered history with OSHA when it comes to some of the specialized saws and disassembling equipment common at pallet plants. While most inspectors will accept the manufacturer's design and original guards, coupled with worker training on safe work practices, others may seek to have guards retrofitted and this can interfere with proper operation of the equipment. Since retrofit can require engineering expertise and can also invalidate manufacturer warranties, outside assistance may be needed to properly defend against such citations. Powered industrial trucks — including forklifts — also trigger a lot of OSHA citations, mostly involving lack of operator training and certification. But this equipment must be maintained in safe working condition, care must be exercised around battery charging stations, and OSHA has been known to cite the absence of seat belts under its General Duty Clause. The remaining top cited general industry standards involve electrical wiring. Often, employers are cited for improperly performed "field repairs" of plugs and cords, as well as for extended use of temporary wiring, wires that run over doors or through wet areas, or improperly rated equipment. In general, to avoid OSHA electrical citations, it is best to hire a reputable, licensed electrical contractor to perform this work. On the rulemaking side of OSHA, the next final rule out of the gate will likely be the electronic recordkeeping requirement, which is currently at the Office of Management and Budget (OMB) awaiting clearance. As proposed, the new recordkeeping regulation would require all employers to submit workplace injury and illness records electronically. Employers with more than 250 employees would submit their data quarterly, while smaller employers would turn in their information annually. OSHA would then post all employer data concerning workplace accidents on an online database, in a move some critics have called "public shaming" because the data would be transparent to the public (and lawyers looking for possible lawsuits) with company identifiers, searchable by establishment. OSHA has indicated its desire to have the rule in place for 2016, but any OMB delays could push the effective date out to 2017. Expect litigation against OSHA to accompany this final rule. Another final rule awaiting OMB clearance, likely to take effect in 2016, concerns slip, trip and fall prevention of general industry. This is a highly anticipated general industry rule that will affect most employers and may require revision of slip/skid resistant Expect the top-cited standard, Hazard Communication, to trigger more citations than ever in the coming year.