The following are questions posed to me by clients on various safety and OSHA issues. If you have a nagging safety question, send it to me and I can help you work through it!
Q: Do you know if OSHA has a standard for fire extinguishers, on when they need to get checked? This is a topic at the warehouse where I work and I want to have the correct info. I searched OSHA and could not find what I was looking for.
What you are looking for from OSHA is 29 CFR 1910.157, Portable Fire Extinguishers. The paragraph reads:
1910.157(e)
Inspection, maintenance and testing.
1910.157(e)(1)
The employer shall be responsible for the inspection, maintenance and
testing of all portable fire extinguishers in the workplace.
1910.157(e)(2)
Portable extinguishers or hose used in lieu thereof under paragraph (d)(3)
of this section shall be visually inspected monthly.
1910.157(e)(3)
The employer shall assure that portable fire extinguishers are subjected
to an annual maintenance check. Stored pressure extinguishers do not require
an internal examination. The employer shall record the annual maintenance
date and retain this record for one year after the last entry or the life of
the shell, whichever is less. The record shall be available to the Assistant
Secretary upon request.
1910.157(e)(4)
The employer shall assure that stored pressure dry chemical extinguishers
that require a 12-year hydrostatic test are emptied and subjected to
applicable maintenance procedures every 6 years. Dry chemical extinguishers
having non-refillable disposable containers are exempt from this
requirement. When recharging or hydrostatic testing is performed, the 6-year
requirement begins from that date.
1910.157(e)(5)
The employer shall assure that alternate equivalent protection is provided
when portable fire extinguishers are removed from service for maintenance
and recharging.
To be compliant, usually a monthly check is done to assure the extinguisher
is in place, charged, the carter pin is in place and no sign of leakage. The annual inspection is usually done by an outside company who puts a tag on it.
Q: I have a question on the Confined Space standard. Do I need a 20-page procedure if I'm having an outside contractor ALWAYS do the entering into my confined spaces?
To answer your question, no you do not need a 20-page procedure. I would have one page listing the permit required confined spaces on site. Further, the procedure should state that under no circumstances will the employees enter these spaces. In addition I would train some Maintenance and/or the supervisors on the definition of a permit required confined space (about 10 to 20 minutes of training) so that if a new one is discovered it can be added to the above list and the employees will be instructed not to enter it. Note that you will bring in a contractor to perform all permit required confined space work. Also, state that you will inform the contractor that they are required to comply with all applicable OSHA standards and request a copy of their Permit Required Confined Space procedure. That should cover you.
Q: OSHA says that extension cords can only be used on a temporary basis, what is their definition of temporary?
I formerly quoted after 30 days of use it was no longer considered temporary and was in the permanent realm. To confirm, I talked to the local OSHA office about the 30-day use on extension cords. While he confirmed that they do write people up for using cords as permanent wiring, he said he hadn't heard of the 30-day limit. He said that they take it on a case-by-case basis. He did say that after hearing the 30-day idea, it would be a very good guideline, but in limited cases (you could show equipment is on order, in a month's time a building change was going to happen, etc...) they might consider longer than a month as temporary. This is the definition that a single Compliance Officer used; call your local OSHA office’s On Duty Officer and ask for their interpretation.
Q: I was wondering whether you'd happen to know if there are any regulations that specifically impact the pest control/pesticide and/or landscaping industries with regards to the need for respirator questionnaires, respirator PE's, fit testing, etc?
Actually, EPA has a lot to say on Pesticides. They have some licensing regulations. Yes, they would fall under Haz-Com, PPE, Respirator and such. A dust mask would not be effective enough for pesticides use. EPA will dictate use and application, OSHA would cite if it is not used in a safe (as per OSHA standards) manner.
DOT has approved plastic gas containers, but my understanding is that you cannot bond and ground plastic. How is the plastic dissipating the static if it doesn't ground?
I forwarded this question to ESD Journal and received the following response from Steve Fowler, publisher of the Journal.
You are correct in asking how the container dissipates if it is plastic. The answer is "It doesn't" We are not big proponents of plastic gas cans or plastic gas tanks on cars.
These cans generate high potentials when being filled which cannot go to ground. We have measured as high as 20 kV on 5 gallon cans being filled at full delivery speed. The only thing that makes them not ignite all the time is that they have no metal on them to which a spark can discharge. The most dangerous situation is the mixing of metal and plastic gas cans in the back of a truck. This allows the plastic can to generate the potentials which are induced on the metal can and a discharge occurs when the nozzle is touched to the metal can.
The plastic can being set on the ground will, however, have less potential on it than if it is in the back of a truck. This has nothing to do with dissipation and everything to do with capacitance. The formula is Q=CV. If the can is on the ground, the capacitance is high and the voltage is lower for the same charge. When the can is in the back of a truck, the capacitance is low and the voltage higher. However, it does not dissipate to anywhere from the can.
Main thing to remember is
don't mix metal and plastic cans while filling
put them on the ground
keep the nozzle in the can and in contact with the can (especially with metal cans)
and most importantly
FILL VERY SLOWLY.