Reset of OSHA Annual Requirements

With the turn of the calendar to 2011, it is an opportune time to do a review of the Occupational Safety and Health Administration (OSHA) annual requirements that apply to your company. Among the multitude of OSHA training, inspection and administrative requirements, there are certain regulations which explicitly specify actions that must be taken on an annual basis. Unless these requirements are met each and every year, a facility could be at risk for regulatory enforcement.

Here’s a summary of the significant annual requirements for General Industry that potentially could impact any workplace:

Access to Employee Exposure and Medical Records (OSHA 1910.1020): OSHA requires that employers inform employees on an annual basis of the existence of exposure and medical records, the methods for requesting access to them, and employees’ rights of access to these records.

Automatic Sprinkler Systems and Fixed Extinguishing Systems (OSHA 1910.159, 160, and 161): The main drain flow test for the automatic sprinkler system is to be performed on each system annually. All fixed extinguishing systems are to be inspected annually by a person knowledgeable in the design and function of the system to assure that the system is maintained in good operating condition.

Furthermore, employers must train employees designated to inspect, maintain, operate, or repair fixed extinguishing systems and annually review their training to keep them up-to-date in the functions they are to perform. For dry chemical systems, the dry chemical supply must be sampled at least annually to assure that the dry chemical supply is free of moisture which may cause the supply to cake or form lumps.

Fire Brigades (OSHA 1910.156): If established by the employer, all fire brigade members are to be provided with training at least annually. Fire brigade members who are expected to perform interior structural fire fighting shall be provided with an education session or training at least quarterly. All fire fighting equipment used by company fire brigades must be inspected annually.

Hazardous Waste Operations and Emergency Response (OSHA 1910.120): Annual training applies to employees who will respond to spills, releases, and other emergencies. The level of training required will depend upon the level of response to which affected employees are trained.

Occupational Noise Exposure (OSHA 1910.95): Annual training and audiometric testing is required for employees included in the Hearing Conservation Program who are exposed to noise at or in excess of 85 dBA.

Permit-Required Confined Spaces (OSHA 1910.146): The permit space program must be reviewed using cancelled permits within one year after each entry. For rescue personnel, all affected employees must practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces.

Portable Fire Extinguishers (OSHA 1910.157): Personnel who are required to use fire fighting equipment as part of an emergency action plan must be trained in the use of the appropriate equipment annually. Annual awareness training must be provided for all workplaces where fire extinguishers are provided for use in the workplace. Portable fire extinguishers are subject to an annual maintenance check. A record of the annual maintenance date must be recorded and retained for one year after the last entry or the life of the shell, whichever is less.

Process Safety Management of Highly Hazardous Chemicals (OSHA 1910.119): All operating procedures that fall under the OSHA PSM standard must be certified annually that the procedures are current and accurate.

Respiratory Protection (OSHA 1910.134): All respirator wearers included in a Respiratory Protection Program are required to undergo training and fit testing on an annual basis.

Stand Pipe and Hose Systems (OSHA 1910.158): Hose systems are to be inspected at least annually and after each use to assure that all of the equipment and hose are in place, available for use, and in serviceable condition. Hemp or linen hose on existing systems must be unracked, physically inspected for deterioration, and reracked using a different fold pattern at least annually.

Bloodborne Pathogens (OSHA 1910.1030): Annual training is required for all employees who may be occupationally exposed to bloodborne pathogens. Biosafety Manuals and Exposure Control Plans must be reviewed on an annual basis and the employer is required to document annually any considerations and implementation of commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure. When biosafety cabinets (BSCs) are used for exposure control, the BSCs must be inspected and certified on an annual basis.

The Control of Hazardous Energy (Lockout/Tagout) (OSHA 1910.147): The employer is required to conduct a periodic inspection of each energy control procedure at least annually to ensure that the procedure and the requirements of the OSHA standard are being followed.

Substance-Specific Health Standards for Hazardous Chemicals (OSHA 1910, Subpart Z): OSHA imposes a variety of annual requirements for workplaces where employees are exposed to regulated chemicals above the applicable Action Level or Permissible Exposure Limit (PEL). Examples of regulated chemicals include hexavalent chromium, methylene chloride, and lead. The annual requirements specified in these standards can include Industrial Hygiene monitoring, medical monitoring, and/or other administrative requirements.

Submitted by Compliance Management International
Compliance Management International’s (CMI) Health and Safety Professionals are available to consult with companies on the specific annual requirements that apply to their workplace. We can also assist you in achieving compliance with any aspect of the OSHA regulations in a timely and cost effective manner.

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