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November-December 2015

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24 PalletCentral • November-December 2015 palletcentral.com surfaces in some work areas, reengineering in some situations, training, and new procedures for use of safety harnesses and lanyards or other types of fall prevention systems for work on rolling stock such as flatbed trucks (mobile equipment was exempt under the old standard). The most recent OSHA regulatory agenda also calls for the long awaited combustible dust rule to awake from hibernation, with a small business review panel due in spring 2016. It is unlikely that a final rule can be complete prior to January 2017, when the next administration takes over, but a proposed rule could be promulgated in the coming year. In the meantime, OSHA continues its NEP on combustible dust, with about 25% of citations issued under the General Duty Clause for failure to follow safe work practices such as those included in voluntary consensus standard NFPA 652 (having no more than 1/32" of combustible dust accumulated on horizontal surfaces such as duct work, suspended ceilings, beams and floors. Other OSHA enforcement initiatives, including the Severe Violator Enforcement Program, the war on safety incentives that rely on having no injuries to receive a prize or benefit, and aggressive prosecution of whistleblower violations under Sec. 11C of the OSH Act, are expected to continue in the coming year. OSHA also announced that it will give more "inspection credits" to its area offices for conducting more complex inspections such as those involving ergonomic hazards, workplace violence, and process safety management. There is SAFETY

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