MOSH Hot Topic : Written Hazard Assessments

Every once in a while we get some insight into what the compliance hot topic is. A few years ago it was Eye Wash stations for the mixing of cement. Nevermind the scaffold, look for the eye wash… an non-alkaline soap.

Now the new MOSH hot topic is a Written Hazard Assessment for each jobsite you run and that it is Certified. Now, most companies don’t do this formally, but have a generic one regarding PPE for the workers. Is this a valid citation? Yes. Is it dirty? Yes.

CSM is advising all clients to make sure you have a Written Hazard Assessment for each jobsite you are working noting the hazards that are present and that could become present and what PPE you will be using to mitigate these hazards. Make sure the assessor signs their name on a line stating “Certified by”.

While we’re on the topic, you might as well make sure all of your workers are Trained on the PPE they are using, it’s lifespan, how to store, how to clean, and when it’s no longer working. Document this training as well.

If you have questions about this, get in touch with us. We’d be happy to help.

Here’s what the standard says: 

1910.132(d)

Hazard assessment and equipment selection.
1910.132(d)(1)

The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:
1910.132(d)(1)(i)

Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
1910.132(d)(1)(ii)

Communicate selection decisions to each affected employee; and,
1910.132(d)(1)(iii)

Select PPE that properly fits each affected employee.

Note: Non-mandatory appendix B contains an example of procedures that would comply with the requirement for a hazard assessment.

1910.132(d)(2)

The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.
1910.132(e)

Defective and damaged equipment. Defective or damaged personal protective equipment shall not be used.
1910.132(f)

Training.
1910.132(f)(1)

The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following:
1910.132(f)(1)(i)

When PPE is necessary;
1910.132(f)(1)(ii)

What PPE is necessary;
1910.132(f)(1)(iii)

How to properly don, doff, adjust, and wear PPE;
1910.132(f)(1)(iv)

The limitations of the PPE; and,
1910.132(f)(1)(v)

The proper care, maintenance, useful life and disposal of the PPE.
1910.132(f)(2)

Each affected employee shall demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE.
1910.132(f)(3)

When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (f)(2) of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where:
1910.132(f)(3)(i)

Changes in the workplace render previous training obsolete; or
1910.132(f)(3)(ii)

Changes in the types of PPE to be used render previous training obsolete; or
1910.132(f)(3)(iii)

Inadequacies in an affected employee’s knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill.
1910.132(g)

Paragraphs (d) and (f) of this section apply only to §§ 1910.133, 1910.135, 1910.136, 1910.138, and 1910.140. Paragraphs (d) and (f) of this section do not apply to §§ 1910.134 and 1910.137.

Post A Comment