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Useful Links

OSHA links

Federal OSHA page This page contains links to standards, interpretations, compliance assistance and various software advisors. It also contains a link to a page identifying which states operate state plans. States may, at their option, adopt and enforce their own standards. Federal OSHA requires that state plans be at least as comprehensive and thorough as Federal OSHA regulations, and states may go beyond the federal regulations or develop additional regulations as needed for industries in their states.

OSHA's Safety & Health Statistics Home Page

This is an especially useful page for benchmarking safety performance of one's company against one's industry. It also has the records of OSHA's inspection activity by employer, by industry, and by standard.

OSHA's "Rules of Construction" address the safety responsibilities of prime and sub-contractors on multi-employer worksites.

The OSHA Ergonomics Page

A key question we are sometimes asked is Does the rescission of the OSHA Ergonomics Rule mean that OSHA lacks a basis to cite employers for ergonomic hazards in the workplace? In the absence of a specific standard for citing ergonomics hazards, OSHA may still cite employers for ergonomic hazards under the. "General Duty" clause. In order to be able to cite employers for ergonomic hazards or any hazard under the Act, OSHA must show that the following four conditions are met (See this OSHRC Decision )

  1. A condition or activity in the employer's workplace presents a hazard to employees,

  2. The cited employer or the employer's industry recognizes the hazard,

  3. The hazard is causing or likely to cause death or serious physical harm, and

  4. Feasible means exist to eliminate or materially reduce the hazard.

And how does OSHRC interpret these requirements for ergonomic hazards? Two key decisions which govern whether a “General Duty” citation for ergonomic hazards will be upheld are the Pepperidge Farms Decision and the Beverly Enterprises Decision. The key sticking point that OSHRC noted with respect to these decisions was how much mitigation of the ergonomic hazard was adequate to not be in violation. The decisions basically grant OSHA the authority to require an employer to engage in an "abatement process, the goal of which is to determine what action or combination of actions will eliminate or materially reduce the hazard, but in order to sustain the 5(a)(1) citation, OSHA must establish that the abatement process that the employer conducts is inadequate." OSHA has cited employers for ergonomic hazards, but the citations appear to be concentrated in a few specific offices. You can click over the OSHA site and search for “General Duty” clause citations. “ergonomics” in the Query field. OSHA maintains a list of industry-specific and task-specific interventions. While OSHA says that deviation from these ergonomics guidelines will not necessarily be considered evidence of a violation, there was an increase in inspections and citations of nursing homes following the issuance of ergonomics guidelines for nursing homes. If OSHA has issued guidelines for your industry, it would be prudent to attempt to incorporate their suggested practices.

As a helpful aid for your ergonomics effort, you may wish to download this calculator for the NIOSH Lifting Equation Guidelines written by one of J.P. Purswell"s students at Colorado State University in Pueblo. It does require that you have installed some Visual Basic run time routines on your PC.

California, which has a state plan, has adopted a repetitive motion standard, also known as the Cal-OSHA ergonomics standard This page contains both the text of the standard and a brief history on how it has been implemented and litigated.

Selected NIOSH Publications

National Institute of Occupational Safety and Health (NIOSH) is charged with (among other things) performing or funding the research that is used by OSHA to support its standards.

The NIOSH review of the effectiveness of occupational safety and health training summarizes the literature on the effect of safety training on accidents rates and observed safety behaviors.

The large scale epidemiological review by NIOSH concerning the work-relatedness of musculo-skeletal disorders.

The Applications Manual for the Revised NIOSH Lifting Equation

The NIOSH "Elements of Ergonomic Programs"

Transcripts of presentations at NIOSH conference entitled "Ergonomics: Effective Workplace Practices and Programs

The NIOSH statement on keyboard designs

Systematic Reviews of Childhood Injury Prevention Interventions:

National Center for Injury Prevention and Control, part of the Centers for Disease Control

The (brief) NIOSH statement on backbelts

There is also a more detailed NIOSH review of backbelts.

Some Useful Transportation-Related Safety Links

The US Department of Transportation

The National Highway Traffic Safety Administration (NHTSA)

NHTSA report entitled "The Effectiveness of Retroreflective Tape on Heavy Trailers"

NHTSA's compliance testing for motorcycle helmets, and child restraints, and for front-impact and side impact of vehicles

Federal Motor Carrier Safety Regulations

The Snell Memorial Foundation is a not-for-profit organization dedicated to research, education, testing and development of helmet safety standards.

This is a page with a list of the current Snell standards.

The Federal Railroad Administration

The Association of American Railroads

The US Naval Observatory's page has a useful little program for calculating sunrises, sunsets, moonrises, and moonsets for any US city or any latitude and longitude by date.

Resources that Deal with Chemical Characteristics, Hazards, and Permissible Exposure Levels.

The National Safety Council maintains this site on Computer-Aided Management of Emergency Operations.

This site accepts chemical name, CAS Number, molecular formula, or molecular weight and returns physical characteristics (melting and boiling points, evaporation rates, etc.) as well as reference numbers (CAS numbers, RTECS number, EPA code, and DOT number). Handy if one is trying to review or write an Material Safety Data Sheet or review the adequacy of an existing one.

This page contains information on a number of chemicals that have been evaluated by the National Toxicology Program.

The National Oceanic and Atmospheric Administration has free program to assess the reactivity of substances and mixtures called the Chemical Reactivity Worksheet

The DOT Hazmat regs

The US Fire Administration has prepared this Hazardous Materials Guide

The National Fire Protection Association (NFPA) maintains this page

16 CFR 1500 - CPSC regulations relating to the Federal Hazardous Substances Act

Letter of Intepretation issued by the CPSC regarding the inapplicability of the FHSA to chemicals not sold or intended for home use

The Law.com website has this analysis of a ruling concerning the pre-emption of state statutes regarding labeling of a flammable chemical by the Federal Hazardous Substances Act

Order page for ANSI Z 129.1, Hazardous Industrial Chemicals - Precautionary Labeling

The Hazard Communication Standard sets out the training and other requirements for employers of workers who may be exposed to hazardous or toxic chemicals. Section 3 of the preamble to the Hazard Communication Standard contains some interesting and illuminating comments by OSHA on the (lack of) effectiveness of warning labels in the absence of proper training and supervision. The following comments are excerpted from this section.

Some of the comments on the role of labels versus data sheets revealed a lack of information on the part of the participants regarding available research on the role of labeling. For example, one commenter indicated that there are "hundreds" of studies that indicate labels are effective, and thus the preferred means of transmitting information (Ex. 11-108). When asked during the hearing to provide a bibliography of these studies (Tr. 3-182), the American Dental Trade Association suggested that OSHA consult the ANSI labeling standard for such a bibliography.

The ANSI labeling standard does not contain any such information. The one study referenced is one on symbols that was conducted in conjunction with the development of the standard. That study concluded that many commonly used symbols are not well - recognized, and thus are not effectively transmitting hazard information. Based on that study, the ANSI committee decided not to include requirements for symbols in the standard. Ex. 49.

The chairman of the ANSI committee testified on behalf of the Chemical Manufacturers Association (Tr. 6-6-39). He is also chairman of the Board of a professional society (formerly the American Conference on Chemical Labeling but now the Society for Chemical Hazard Communication) of experts on labeling and material safety data sheets. OSHA asked him if he or the ANSI committee were aware of "hundreds" of studies regarding the effectiveness of labels, and he replied: "No, I am not aware of any studies of that nature." Tr. 6-29. Mr. Talcott further indicated that "a full hazard communication program really includes the label, a properly constructed label, but it has other parts. And the data sheet, as well as the hazard determination and training programs serve very vital parts in that full hazard communication program. And I think OSHA has properly recognized that there are multiple parts, and a label alone is not going to be a full hazard communication program." Tr. 6-28-29.

In fact, although there have been various labeling requirements and practices for many years, there is little evidence that labeling results in a change in behavior without the availability of other information and communication mechanisms. See Ex. 71-23A, Handbook of Chemical Industry Labeling: "[T]he editors have found no published research which clearly isolates the effect of a given label on a specific chemical product from the effects of other factors including inserts, training, general media information, advertising and promotion or consumerist activities."

It should also be noted that it was suggested that the labeling requirements of the ANSI standard result in enough information for workers. Yet the ANSI committee specifically addressed this issue in the preamble to the standard: "Precautionary labels are not intended to include all information on the properties of a chemical nor the complete details of its handling under all conditions. Such information is more appropriately provided through other means, such as material safety data sheets, technical bulletins, training, or other communications intended to enhance and supplement the label." Ex. 49.

Clearly, the genesis of many of the comments received opposing the MSDS requirements is simply that these commenters do not want to deal with them, rather than any objective evidence that they are not necessary. As has been discussed at length in previous HCS Federal Register documents (see preambles to original NPRM and final rule), the effectiveness of a hazard communication program relies on the three-pronged approach in the HCS (labels, MSDSs, and training). Each serves a different purpose, and they are all interdependent on each other. No information provided during this rulemaking proceeding has altered that finding.

The Consumer Product Safety Commission Website, including online access to the National Electronic Injury Surveillance System (NEISS) database and the 1975 and 1977 studies on the anthropometry of children.