Choose the right fall protection training partner

Original article published by Safety+Health

Who needs fall protection training? How often should it occur? Who can best conduct it, and does one size fit all?

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Photo: Diversified Fall Protection

Responding is Kevin Kelpe, brand manager, Diversified Fall Protection, Westlake, OH.

In 2017, OSHA made sweeping updates to its standards on walking-working surfaces in general industry and personal fall protection systems (1910.140). Although the changes in the final rule affect manufacturers, employers and workers in many ways, some of the most important changes pertain to training and other fall protection services. Although these services are more expertise than equipment, they can best be provided by a fall protection integrator with practical experience designing and installing systems, and not an all-purpose training company. Not all training is created equal (even if it’s technically compliant).

OSHA’s 1910.30 standard requires employers to train employees on fall hazards and fall protection equipment, and to retrain these employees at regular intervals. Employers in general industry are also required to designate authorized, competent and qualified persons (three separate designations in the rule) who use, supervise the use of and install fall protection systems, respectively. And that’s not all! The rule now requires that anchorage connectors used for travel restraint, fall arrest and suspended access be inspected, tested, certified and recertified at varying intervals (1910.27 and 1910.140). The updated rule requires documentation produced during these activities to be maintained by building owners and made available for contractors who work on their properties.

Whew! Considering all of this, it’s easy to see why a company offering just one element of fall safety may not cut it. The most appropriate partner for employers would, first, have broad experience with eliminating hazards. They would then have hands-on experience designing solutions using their own products and those of other manufacturers, and experience installing and certifying those integrated systems. Employers should seek out an organization with many regional locations that put the required personnel in their backyard – a regional team of engineers, inspectors and trusted advisors to demystify compliance and give employers peace of mind. Employers also capture economies of scale if they can use the same provider for the equipment and all of the services required by law (to be clear, that’s training, inspection, testing and certification).

The 2021 Fall Experience Survey developed by the American Society of Safety Professionals further illuminated the employer’s need for access to deeper expertise. Survey respondents cited a lack of planning as the leading cause of falls. Also among the top 10 causes were a lack of training and competency programs. ASSP found that, in many cases, building owners had installed fall protection systems, but those systems were inappropriate for the circumstances in which the work was done. Or, in other cases, workers used connectors that were incompatible with the equipment installed and were injured even though they were trained and tied off, albeit improperly.

This may seem surprising, but it’s understandable; in recent years, many products promising more efficient compliance have become available. The market has responded to new regulation with lots of rapidly evolving technology. Indeed, we may be in the golden age of fall safety.

Paradoxically, however, this influx of options may be widening the gap between workers and safety for a time, as the market catches up to match employers with newly minted experts. This further emphasizes the need for a true partnership. A transactional relationship between providers and employers is no longer a suitable option to protect workers or businesses. Employers now, more than ever, require subject matter experts in fall safety. They require fall protection partnership for life.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

OSHA extends comment period on proposal to amend rules on workplace lead exposure

First published by Safety+Health an NSC publication

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Washington — In response to multiple stakeholder requests, OSHA has extended until Oct. 28 the comment period on a proposed rule that would revise the agency’s standards on occupational exposure to lead in general industry and construction.

According to a notice published in the Aug. 18 Federal Register, the extension provides stakeholders additional time to collect information and data necessary to submit responses and comments. The initial deadline was Aug. 29.

OSHA, in the June 28 Federal Register, published an advance notice of supplemental proposed rulemaking seeking input on blood lead levels for medical removal and return to work, as well as:

  • Medical surveillance provisions, including triggers and frequency of blood lead monitoring
  • Permissible exposure limits
  • Ancillary provisions for personal protective equipment, housekeeping, hygiene and training

The agency’s blood lead level for medical removal is 60 micrograms per deciliter or more for general industry and 50 micrograms per deciliter or more in construction. The return-to-work BLL is less than 40 micrograms per deciliter.

OSHA adopted its standards on lead exposure for general industry and construction in 1978 and 1992, respectively. Since then, studies by the American Conference of Governmental Industrial Hygienists, the Environmental Protection Agency, and the Association of Occupational and Environmental Clinics, among other organizations, have indicated that adverse effects can occur at lower BLLs.

“For example, BLLs as low as 5 μg/dL have been associated with impaired kidney and reproductive function, high blood pressure, and cognitive effects attributed to prenatal exposure,” the ANPRM stated. “Poorer performance on neurocognitive and neuropsychologic assessments were observed in adults with BLLs as low as 5-19 μg/dL compared with adults with BLLs below 5 μg/dL.”


McCraren Compliance assists employers in protecting their workers, starting with a comprehensive Work-site Analysis, Hazard Prevention, Controls, and Safety & Health Training.

Please contact us today at 888-758-4757 to learn how we can provide mine safety training and consulting for your business.

HazCom standard update coming before year’s end? Spring 2022 regulatory agenda released

First published by Safety+Health an NSC publication

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Photo: Office of Information and Regulatory Affairs

Washington — An update to OSHA’s Hazard Communication standard could happen as soon as December, according to the Department of Labor’s Spring 2022 regulatory agenda.

Published June 21, the agenda – issued by the Office of Information and Regulatory Affairs twice a year – provides the status of and projected dates for all potential regulations listed in three stages: pre-rule, proposed rule and final rule.

In this latest regulatory agenda, the HazCom standard update was moved from the proposed rule stage to the final rule stage.

OSHA’s current Hazard Communication standard (1910.1200) is linked with the third edition of the Globally Harmonized System of Classification and Labeling of Chemicals, also known as GHS. In February 2021, OSHA issued a proposed rule to update the regulations to align with GHS’ seventh edition.

Also listed in the final rule stage is a permanent COVID-19 standard for the health care industry. That’s expected to appear sometime in the fall, OSHA administrator Doug Parker and Labor Secretary Marty Walsh indicated in separate Congressional hearings in the past four weeks.

OSHA’s Infectious Diseases standard, meanwhile, is listed in the proposed rule stage, with a notice of proposed rulemaking slated for May at the earliest.

OSHA’s Emergency Response standard moved from the prerule to the proposed rule stage, and a notice of proposed rulemaking is not expected to appear until at least May as well. That regulation will attempt to “address the full range of hazards or concerns currently facing emergency responders, and other workers providing skilled support,” and provide performance specifications for protective clothing and equipment.

Meanwhile, the agency is reopening the rulemaking record on clarifying parts of its Walking-Working Surfaces standard. The agency planned to correct a formatting error in Table D-2 of that regulation and “revise the language of the requirements for stair rail systems to make them clearer and reflect OSHA’s original intent.”

The regulation was in the final rule stage in the Fall 2021 regulatory agenda, released Dec. 10, but is now back to the proposed rule stage.

OSHA’s attempt to revise Table 1 of its silica standard for construction was moved from the proposed rule stage to the list of long-term actions. That means the agency isn’t expected to perform any work on that standard for at least six months.

The Mine Safety and Health Administration had one change from the Fall 2021 regulatory agenda: A final rule requiring written safety programs for mobile equipment and powered haulage at surface mines or “surface areas of underground mines” could appear in October.


McCraren Compliance assists employers in protecting their workers, starting with a comprehensive Work-site Analysis, Hazard Prevention, Controls, and Safety & Health Training.

Please contact us today at 888-758-4757 to learn how we can provide mine safety training and consulting for your business.

OSHA begins rulemaking process to revise standards for occupational exposure to lead

First published by OSHA

WASHINGTON – The U.S. Department of Labor announced that its Occupational Safety and Health Administration has published an Advance Notice of Proposed Rulemaking to revise its standards for occupational exposure to lead.

Recent medical research on workplace lead exposure shows adverse health effects can occur in adults at lower blood lead levels than recognized previously in the medical removal levels specified in OSHA’s lead standards.

The ANPRM seeks public input on modifying current OSHA lead standards for general industry and construction to reduce the triggers for medical removal protection and medical surveillance and prevent harmful health effects in workers exposed to lead more effectively.

OSHA asks the public to comment on the following areas of the lead standards:

  • Blood lead level triggers for medical removal protection.
  • Medical surveillance provisions, including triggers and frequency of blood lead monitoring.
  • Permissible exposure limit.
  • Ancillary provisions for personal protective equipment, housekeeping, hygiene and training.

The ANPRM will also gather comments on employers’ current practices that address workplace lead exposure and associated costs and other areas of interest.

Read the Federal Register notice for submission instructionsSubmit comments online by Aug. 29, 2022, on the federal e-Rulemaking portal and refer to Docket No. OSHA-2018-0004.


McCraren Compliance assists employers in protecting their workers, starting with a comprehensive Work-site Analysis, Hazard Prevention, Controls, and Safety & Health Training.

COVID-19 and health care workers: Walsh reiterates that permanent rule likely before year’s end

First published by Safety+Health an NSC publication

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Photo: Senate Appropriations Labor, Health and Human Services, Education and Related Agencies Subcommittee

Washington — Echoing comments made by OSHA administrator Doug Parker during a hearing three weeks earlier, Labor Secretary Marty Walsh said a permanent standard on COVID-19 for the health care industry may be published sometime in the fall.

Walsh testified before the Senate Labor, Health and Human Services, Education, and Related Agencies Subcommittee on June 15 – a day after appearing before the House Education and Labor Committee.

During the June 15 hearing, Sen. Patty Murray (D-WA), chair of the subcommittee, asked Walsh for an update on the forthcoming permanent standard. OSHA withdrew the non-recordkeeping parts of its emergency temporary standard for COVID-19 focused on health care workers Dec. 27 – around six months after it first went into effect.

“I believe it will be done in the next three to six months.” Walsh said.

“Three to six months from now?” Murray asked.

“Yes. It’s the rulemaking process,” Walsh responded. “I would love to speed it up, but, unfortunately, it’s the process that’s in place that we have to work under.”

Walsh also noted that OSHA is continuing its work on a standard on infectious diseases. According to the Department of Labor’s latest regulatory agenda, issued Dec. 10, that standard would be aimed at the health care industry and other “high-risk environments.”

The Office of Information and Regulatory Affairs is expected to publish an updated regulatory agenda in the near future.

Mining deaths

During both hearings, Walsh highlighted a recent increase in mine worker fatalities. The labor secretary told Sen. Shelley Moore Capito (R-WV) and Rep. Teresa Leger Fernandez (D-NM) separately that his department had a call with “some of the major mining companies in America” to talk about sharing best practices on safety.

According to the Mine Safety and Health Administration, 37 mining fatalities were recorded last year – up from 29 in 2020. As of June 15, the agency had reported 12 miner deaths this year.

“Something I did when I was the mayor of Boston when we had high shootings is we brought all the stakeholders to the table. We did the same thing with the mining industry,” Walsh told Capito. “We need to make sure we stay on top of it.”


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

Control Hazardous Energy: 6 Steps

First published by Safety+Health an NSC publication

Photo: OSHA

A mainstay on OSHA’s Top 10 list of most cited violations is the standard on lockout/tagout (1910.147).

Simply put, “lockout/tagout is a safety procedure used to make sure equipment and machines are properly shut off and not able to start during maintenance or repair work,” the Texas Department of Insurance says. “This is known as controlling hazardous energy.”

Help prevent the unexpected release of stored energy with these six steps from TDI:

  1. Prepare. An authorized employee, defined by OSHA as “a person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment,” must identify and control all potential forms of hazardous energy.
  2. Shut down. Turn off the equipment using the proper procedures. Inform all employees who use the equipment about the shutdown.
  3. Isolation. Isolate equipment from energy sources. This may mean turning off power at a breaker.
  4. Lock and tag. Apply a lockout device to keep equipment in an energy-isolating position. Then, place a tag on the device with the authorized employee’s name who performed the lockout.
  5. Check for stored energy. Hazardous energy can remain in the equipment even after the energy source has been disconnected and the machine has been locked out.
  6. Verify isolation. Check again to ensure the equipment is isolated and deenergized before service or maintenance begins.

McCraren Compliance assists employers in protecting their workers, starting with a comprehensive Work-site Analysis, Hazard Prevention, Controls, and Safety & Health Training.

Please contact us today at 888-758-4757 to learn how we can provide mine safety training and consulting for your business.

NIOSH to employers: Are you inspecting your lockout/tagout procedures?

First published by Safety+Health an NSC publication

NIOSH to employers Are you inspecting your lockout/tagout procedures
Photo: OSHA

Washington — Pointing to OSHA guidance citing “the significant risks associated with inadequate energy control procedures or the failure to properly implement them,” NIOSH is reminding employers that OSHA’s standard on lockout/tagout (1910.147) requires them to conduct an inspection of written hazardous energy control procedures at least once a year.

In fiscal year 2021, lockout/tagout ranked sixth on OSHA’S Top 10 list of most frequently cited standards, with 1,670 total violations, according to preliminary OSHA Information System data.

Within the standard, 1910.147(c)(6) – “periodic inspection” – was the third most frequently cited section, with 255 violations. In fourth, with 162 violations, was 1910.147(c)(1), which reads: “The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperable.”

NIOSH offers tips and reminders for developing and maintaining a lockout/tagout program:

  • Include in written energy control procedures elements such as the scope of procedures; intended purpose; names of authorized personnel; rules for shift change, transfer of locks, etc.; and specific methods used to control hazardous energy.
  • A periodic inspection must include a demonstration of the procedures and be conducted while the authorized employee performs service/maintenance on a machine/equipment.
  • Each energy control procedure must be separately inspected to ensure the procedure is adequate and properly implemented by the authorized employee.
  • The inspector must be a lockout/tagout-authorized employee who is knowledgeable and isn’t currently performing lockout/tagout on the energy control procedure under inspection.
  • The inspector can’t implement any part of the procedure during the inspection, and must observe the implementation of the lockout/tagout procedure for the equipment or machine being evaluated and speak with at least one authorized employee who is implementing the procedure to ensure they understand the procedure.
  • If the periodic inspection process reveals deviations from the written procedures or inadequacies in an employee’s knowledge of procedures, the employee must be retrained.

NIOSH guidance document features recent case studies that detail separate workplace fatalities related to improper lockout/tagout processes.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

OSHA Withdraws Vaccination and Testing ETS

First published by OSHA

Man receiving vaccination

Photo: OSHA

Statement on the Status of the OSHA COVID-19 Vaccination and Testing Emergency Temporary Standard 

The U.S. Department of Labor’s Occupational Safety and Health Administration is withdrawing the vaccination and testing emergency temporary standard issued on Nov. 5, 2021, to protect unvaccinated employees of large employers with 100 or more employees from workplace exposure to coronavirus. The withdrawal is effective January 26, 2022.

Although OSHA is withdrawing the vaccination and testing ETS as an enforceable emergency temporary standard, the agency is not withdrawing the ETS as a proposed rule. The agency is prioritizing its resources to focus on finalizing a permanent COVID-19 Healthcare Standard.

OSHA strongly encourages vaccination of workers against the continuing dangers posed by COVID-19 in the workplace.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

Supreme Court mulling decision on OSHA’s ETS on COVID-19

First published by Safety+Health an NSC publication

Washington — Who gets to decide how to protect workers against COVID-19? That was one of the central questions posed by opponents of OSHA’s emergency temporary standard on COVID-19 vaccination, testing and masking during a Jan. 7 hearing before the U.S. Supreme Court.

Scott Keller, attorney for the National Federation of Independent Business, presented the question in a response to questioning from Justice Stephen Breyer early in the two-hour hearing. “You said the question is, ‘Who decides?’” Justice Elena Kagan said to Keller later in the hearing. “I think that’s right. I think that is the question.”

Kagan contended in her questioning that OSHA has experts on workplace safety and is politically accountable to the public via the election of presidents and representatives in Congress.

“Courts are not politically accountable,” she said. “Courts have not been elected. Courts have no epidemiological expertise. Why in the world would courts decide this question?”

Keller and Ohio Solicitor General Benjamin Flowers contended that Congress didn’t give OSHA clear authority to address vaccinations in the Occupational Safety and Health Act of 1970. The duo also argued that states and private businesses can decide how to protect workers from COVID-19.

Chief Justice John Roberts expressed similar thoughts to U.S. Solicitor General Elizabeth Prelogar, who was arguing on behalf of the government.

“It sounds like the sort of thing that states will be responding to, or should be, and Congress should be responding to, rather than agency by agency of the federal government and the executive branch acting alone.”

Justice Sonia Sotomayor mentioned that “certain states … are stopping employers from requiring vaccines” and masks.

“Why shouldn’t the federal government, which … Congress has decided to give OSHA the power to regulate workplace safety, have a national rule that will protect workers?” she asked.

Reading from the OSH Act, Sotomayor noted that Congress gave OSHA the authority to develop “innovative methods, techniques and approaches for dealing with occupational health and safety problems.”

Prelogar pointed to Section 20(a)(5), which reads: “Nothing in this or any other provision of this act shall be deemed to authorize or require medical examination, immunization, or treatment for those who object thereto on religious grounds, except where such is necessary for the protection of the health or safety of others.”

OSHA extends comment period for COVID-19 ETS

First published by Safety+Health an NSC publication

Washington — OSHA has extended until Jan. 19 the comment period on its emergency temporary standard on COVID-19 vaccination, testing and masking.

According to a Nov. 30 press release, the extension allows stakeholders additional time to review the ETS as well as collect information and data necessary for comment. OSHA published the ETS in the Nov. 5 Federal Register, with the initial comment period slated to end Dec. 6.

The fate of the ETS is still unclear. The 5th U.S. Circuit Court of Appeals halted the implementation and enforcement of the rule by granting a stay Nov. 12. The 6th Circuit Court of Appeals is slated to consider a consolidated challenge to the ETS in the near future.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.