Audit, Compliance and Risk Blog

OSHA identifies 10 most frequently cited violations

Posted by Jon Elliott on Mon, Jul 25, 2022

The US federal Occupational Safety and Health Administration (OSHA) has published its annual list of the “Top 10 Most Frequently Cited Standards” for fiscal year (FY) 2021. The tabulation covers October 1, 2020 through September 30, 2021; OSHA delays its annual publication to allow time for inspections during a fiscal year to produce citations if appropriate. (I wrote about OSHA inspection procedures and priorities HERE). The remainder of this note summarizes the new list.

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Tags: Health & Safety, OSHA, Workplace violence, violations, safety violations

California again considering requirements for workplace violence prevention

Posted by Jon Elliott on Mon, Jun 27, 2022

On May 22, California’s Division of Occupational Safety and Health (DOSH, but generally referred to as “Cal/OSHA”) issued its latest revised discussion draft of a regulatory standard mandating workplace violence prevention (WVP) steps for employers in “general industry” (potential 8 CCR 3343). This draft revives an effort that began in 2017, when the California Occupational Safety and Health Standards Board (OSHSB) responded to a schoolteacher’s petition that the state enact a WVP standard for educational settings by agreeing to consider one for all settings not covered by its standard for WVP in healthcare settings (which I wrote about HERE). The remainder of this note discusses the latest draft.

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Tags: Health & Safety, Workplace violence, Cal/OSHA

California continues temporary requirements for COVID vaccination and testing

Posted by Jon Elliott on Mon, Jun 06, 2022

As public and occupational health agencies around the world continuously reevaluating their responses to the developing COVID-19 pandemic, California has again weighed in on the side of continuing formal controls. Effective May 5, 2022, California has revised and extended its COVID-19 Prevention Emergency Temporary Standard (ETS) until January 1, 2023. (I wrote about the most recent previous iteration adopted in February HERE). The ETS is presented as 5 rules, which are administered by California’s Division of Occupational Safety and Health (DOSH, but universally called Cal/OSHA). The remainder of this note summarizes these revised standards, which appear in Title 8 of the California Code of Regulations (CCR):

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Tags: Health & Safety, OSHA, Safety and Health at Work, Covid-19, workplace safety, California, Vaccination, Healthcare

OSHA proposes to revise Injury and Illness reporting requirements

Posted by Jon Elliott on Mon, Apr 11, 2022

The Occupational Safety and Health Administration (OSHA) requires most employers with 10 or more employees at an “establishment” to prepare and maintain records of occupational injuries and illnesses (I&I) as they occur (I&I Logs). OSHA also requires employers to post an annual I&I Summary in each workplace “establishment” by February 1, summarizing that workplace’s I&Is during the previous calendar year. In addition, beginning in 2017 OSHA requires some employers to submit some of this I&I information electronically to the agency. (I wrote about the initial electronic reporting requirements HERE). On March 30 OSHA proposed to update and revise these electronic reporting requirements, which the remainder of this note summarizes.

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Tags: Health & Safety, OSHA

California Injury and Illness Prevention Program requirements

Posted by Jon Elliott on Mon, Mar 14, 2022

Although the federal Occupational Safety and Health Administration (OSHA) only recommends that employers create comprehensive safety and health programs, California and a handful of other states require employers to do so. (I wrote about OSHA’s latest recommendations HERE). The remainder of this note summarizes California’s Injury and Illness Prevention Program (IIPP) requirements, which are administered by the state’s Division of Occupational Safety and Health (DOSH; known universally as Cal/OSHA).

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Tags: Health & Safety, OSHA, Safety and Health at Work, workplace safety, California, Healthcare

OSHA laboratory standard

Posted by Jon Elliott on Mon, Mar 07, 2022

According to the Occupational Safety and Health Administration (OSHA), half a million Americans work in “laboratories.” For more than 30 years, OSHA has administered its “Occupational exposure to hazardous chemicals in laboratories” standard – usually just called the Laboratory Standard – to protect employees “engaged in the laboratory use of hazardous chemicals” (29 CFR 1910.1450). The rest of this note discusses these requirements.

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Tags: Health & Safety, OSHA, Hazard Communication

After more than 50 years, OSHA proposes newer and more flexible standards for forklifts

Posted by Jon Elliott on Mon, Feb 28, 2022

The Occupational Safety and Health Administration (OSHA) has proposed revisions to its Powered Industrial Trucks Standard – more often referred to as the “Forklift Standard” since those are the most common types (29 CFR section 1910.178 (general industry) and 1926.602 (construction)). OSHA first adopted the standard in 1971, and most recently revised it in 2017. However, as discussed below, OSHA has never updated the Standard’s principal technical standards during more than half a century. The remainder of this note summarizes the existing requirements, and identifies proposed revisions.

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Tags: Health & Safety, OSHA

Latest National Toxicology Program Report on Carcinogens adds 8 substances

Posted by Jon Elliott on Mon, Feb 14, 2022

The US National Toxicology Program (NTP) has issued its 15th Report on Carcinogens (RoC), adding eight new substances; NTP now identifies 256 chemical, physical, and biological agents; mixtures; and exposure circumstances as “known or reasonably anticipated to cause cancer in humans.” NTP operates within the National Institute of Environmental Health Sciences (NIEHS), which is a unit of the National Institutes of Health (NIH). It was established in 1978 to:

 

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Tags: Health & Safety, NTP, toxicology

California continues temporary requirements for COVID vaccination and testing

Posted by Jon Elliott on Mon, Feb 07, 2022

Although the Occupational Safety and Health Administration (OSHA) has been forced by court action to convert its would-be “emergency temporary standard (ETS)” under which large employers would have been required to protect unvaccinated employees from COVID-19 infections into a proposal (I wrote about the initial ETS HERE), some states can and are moving ahead with similar requirements. Notably, California’s Division of Occupational Safety and Health (DOSH, but universally called Cal/OSHA) recently revised and renewed its own COVID-19 ETSs. The remainder of this note summarizes these standards, which cover five sections of Title 8 of the California Code of Regulations (CCR):

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Tags: Health & Safety, OSHA, Safety and Health at Work, Covid-19, workplace safety, California, Vaccination, Healthcare

OSHA Voluntary Protection programs

Posted by Jon Elliott on Mon, Jan 31, 2022

 The US federal Occupational Safety and Health Administration (OSHA) administers “Voluntary Protection Programs” (VPPs) to encourage employers to establish and implement voluntary worker Safety and Health Programs that exceed minimal efforts to comply with applicable OSHA standards.  As its name states, participation in any VPP is voluntary.  They are designed to encourage employer/employee/OSHA cooperation, and to reward such cooperation by granting employers increased flexibility and reduced likelihood of inspection. VPP sets performance-based criteria for a managed safety and health system, invites sites (and discrete mobile workforces) to apply, and then assesses applicants against these criteria. OSHA provides for full participation (the “Star” program) for sites/workforces that meet all criteria, conditional participation where an employer claims to meet some VPP criteria by non-standard methods (the “Demonstration” program), and qualified participation where the employer fully meets some VPP criteria and has definite plans to meet others (the “Merit” program).

The remainder of this note summarizes VPP criteria and provides additional information about the status of the programs.

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Tags: Health & Safety, OSHA, Safety and Health at Work, workplace safety, VPP