Although nowhere near as exciting as tales of Bigfoot or handy ancient aliens who enjoyed building pyramids in their spare time, there are some persistent OSHA-related myths which are just as untrue. There are so many there’s not room enough in one column for them all, so we’re just covering a sample. Here are some of those myths, plus one item which is completely true – try to guess which one before you get to the answers which follow.
Myth #1: Once a hazardous chemical is no longer in use, the safety data sheet must be kept on file for at least thirty years.
Myth #2: If your permit-required confined space rescue plan is to call the fire department, you have to make sure they’re trained and equipped, make sure they can get there in time, inform them of the hazards they may encounter at the site, and allow them access to your facilities for practice runs in the space.
Myth #3: OSHA’s important rules on Chemical Hazard Communication, Lockout and Permit Required Confined Spaces all require initial training for employees, and annual refresher training thereafter.
Myth #4: Having in-house janitorial staff in an industrial plant or having an employee cut themselves once in a while makes it necessary to implement a Bloodborne Pathogens Exposure Control Program.
Myth #5: Forklift retraining is required for all operators every three years.
Myth #1: Busted! A record of any incident involving a hazardous substance must remain on file for 30 years and there must be some form of exposure record, such as an inventory list of the chemicals on site. An SDS not associated with a specific exposure incident would not need to be retained. – see 1910.1020(c)(5)(iv) for more details.
Myth#2: All quite true. I have been on site during at least one confined space rescue where everything that could go wrong went wrong, and it was all because the employer put zero effort into planning rescue because they thought the local FD could do it. A life-or-death rescue event is the worst possible way to find out you’re not ready for a rescue. See 1910.146(k)(1) for details.
Myth #3: Busted! Although some rules require annual refreshers, Chemical Hazard Communication, Lockout and Permit Required Confined Spaces don’t require annual retraining. See 1910.1200(h)(1), 1910.147(c)(7)(iii)(A) and 1910.146(g)(2) for details.
Myth #4: Busted! OSHA has stated they don’t generally expect janitors in non-clinical settings to have the “reasonably anticipated” exposure to blood or OPIM which triggers Bloodborne Pathogens compliance. The same applies for the occasional cut finger, which could happen anywhere. Oddly, OSHA seems to have forgotten to say much about what is actually a far more common situation than the hospitals, clinics and labs which this rule was mainly written for. You should have a few people trained and equipped for BBP who can clean up blood, and my clients go overboard and train their employees on awareness. See 1910.1030(b), and its many letters of interpretation, for details. Expect to see a lot of statements like “it’s ultimately up to the employer to determine…” avoiding a hard and fast answer.
Myth #5: Busted! An operator evaluation is required every three years. If the evaluation shows no safety deficiencies, no retraining is needed. We do need retraining if there are safety deficiencies, if the type of truck is changed, if the operator was in a near-miss accident, if workplace conditions are changed in ways that would affect safety or if there are various other triggers. See 1910.178(l)(4)(i) for details.
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