I’ve had some phone calls, emails, and texts lately about the status of OSHA standards that are fresh and new, some not so new. So, here’s a rundown of WTH is going on with OSHA’s newest standards, mostly related to my construction friends:
Subpart AA – Construction Confined Space
OK, so this is not “new” since it was published last August! That means it’s enforceable too…There were lawsuits and then there was clarification from OSHA. Nothing was added or taken away from the standard as it was published.
Confined Spaces Litigation Settlement -If you’re in residential construction, this is your best OSHA resource for digesting the standard. This is the 18 page summary and FAQ from OSHA geared towards residential construction confined spaces like attics, basements, and crawlspaces.
OSHA’s Frequently Asked Questions – This is geared towards all employers and follows what your thought process may be as you question what you need to do to comply with the standard.
OSHA’s Confined Space Landing Page – Bookmark this if you have confined space work (yes you, reading this blog post right now), you’ll always know about OSHA’s new and updated materials when you navigate to this site!
Go forth and identify your confined spaces and permit spaces. If you have permit spaces, identify the hazards, controls, and training needs for your personnel.
Know your role(s). Identify where you fit in OSHA’s required communication for permit spaces – Host Employer, Controlling Contractor, and Entry Employer – remember that you may be all of them at once or one at a time, it all boils down to contract language related to your scope of work on a particular site.
Still need help?
I’ve got you covered with downloadable written program and training program templates. I also have tailgate meetings that can be used for such talks or are great for kickoff and preconstruction meetings. If you’re local and download a program, I’ll throw in one hour of onsite consultation. If you’re not local, we can do a phone consultation for an hour.
OSHA’s Digital Recordkeeping Rule
For the sake of word count, please refer to my previous post on the topic with resourceful links here. The first submission year is next year, 2017, for those on OSHA’s list based on high risk industry (per NAICS code) or if you’ve got more than 250 employees.
OSHA’s Crystalline Silica rule
So this is the freshest/newest rule, it took effect on June 23, 2016 and construction has one year to comply. If you have not already, bookmark OSHA’s landing page for the topic, it’s got all of the resources you need in one place.
As with confined space, go forth and identify your hazards! This should be part of a program you’ve already got in place if you have existing respirable crystalline silica hazards in your workplace – now update your program per the OSHA standard. Pay close attention to the new Table 1 – compare your workers’ tasks to the table. If you’re able to fully and properly implement the controls per Table 1, you’re all set! If not, you may have other obligations per the standard.
If you’ve got respirable crystalline silica exposure, you’ll need to develop a written Exposure Control Plan that includes worker training and may include medical monitoring.
Still need help?
I am working on developing downloadable templates similar to the Construction Confined Space products already on my website. Until that time, if you need some help getting started on your written Exposure Control Plan, let’s talk! Leave a comment or contact me directly at firstname.lastname@example.org or 612-567-9981.