Article archive — page 6 of 19
A scissor lift positioned over a required egress route is one citation for the trade and another for the GC under CPL 02-00-124 — up to $165,514 per willful instance. Here is how the coordination gap opens and how to close it.
Running water at the blade isn't a free pass on OSHA's construction silica standard. The Table 1 safe-harbor requires 'fully and properly' implementing the entry — and one misread row collapses the whole program back to paragraph (d).
EPA's May 2026 proposal rescinds the 2024 unmanaged combustion residual leachate limits. Utility EHS leads have a 30-day comment window to make seven specific decisions.
EPA's May 14, 2026 Tier 4 phase-in delay pushes federal vehicle standards to MY 2029 but leaves California and 17 adopting states on the original schedule, splitting dealer compliance.
Property managers think HazCom does not apply to them. CPL 02-00-124 says otherwise — and a single rooftop service call can trigger four citations at up to $16,550 each.
Six reconciliation failure modes — chemical naming, CAS mismatches, max vs average quantity, threshold aggregation, units, and hazard coding — make Tier II forms wrong.
EPA's May 14, 2026 Clean Data Determination for Cleveland's 2015 ozone NAAQS suspends Ohio EPA planning SIPs — but RACT, NNSR, conformity, and anti-backsliding stay in force.
OSHA 1926.502(d) doesn't just require a body harness and a vertical lifeline — it requires them rigged a specific way. Four common ways visible PFAS still gets cited.
One unauthorized drum at the receiving dock can stack four HazCom citations under CPL 02-02-038. Here is the procurement-gate workflow that closes that gap before the PO is issued.
OSHA's five recurring construction-site HazCom citations — written program, SDS access, labeling, training, and inventory — plus how CPL 02-00-124 rolls a sub's failure up to the GC.
EPA's May 13, 2026 proposed rule narrows 'begin actual construction' under NSR/PSD — letting facilities build shells and non-emitting structures in parallel with permit review. Here is the capex schedule it unlocks and the state SIP trap that still controls.
A pre-mobilization SOP for the multi-employer worksite SDS control program construction GCs need to defeat a controlling-employer HazCom citation under CPL 02-00-124.
Water treatment plants run chlorine, sodium hypochlorite, and fluorosilicic acid daily — but generic annual HazCom training rarely covers the three chemicals by name. Here is the training architecture OSHA expects, the PSM/RMP thresholds you cross at 1,500 and 2,500 pounds, and the HCS-2024 deadline closing November 20, 2026.
If a foreign supplier won't provide a compliant Safety Data Sheet, the U.S. business that receives the chemical is the legal importer under 29 CFR 1910.1200 — and inherits authoring liability. Here's what to do when the shipment is on the dock and the SDS isn't.
OSHA shipped a typo in Table D-2 of 29 CFR 1910.28 in 2016 — leaving facility owners guessing whether narrow open stairways need both a stair rail system and a handrail. The February 2026 interim enforcement guidance resolves the question. Here's what to install now.
OSHA 1910.95(h)(1) requires pure-tone air conduction testing for the occupational audiogram. Bone conduction audiometry has a defined clinical follow-up role after a Standard Threshold Shift, but it cannot substitute for the required test. Here is how to build the HCP correctly.
OSHA's January 20, 2026 Letter of Interpretation confirms that burns from personal lithium-ion batteries — including e-cigarette batteries an employee brought from home — are work-related and recordable under 29 CFR 1904.5. Here's the analysis EHS managers need to apply now.
EPA proposed removing North Carolina's vehicle I/M program from the SIP in 18 of 19 counties. What dealerships should reassess before the trigger fires.
Build a defensible chemical substitution program — hierarchy of controls, TSCA Section 6, OSHA General Duty Clause, and a documented alternatives assessment.
Three operational triggers tell you when EPCRA Tier II reporting has outgrown spreadsheets — multi-state filings, SDS turnover, and overlapping EHS reports.
How a sole industrial hygienist clears a chemical risk assessment backlog across multi-plant operations before the November 20, 2026 HazCom deadline.
Why a single round of industrial hygiene sampling fails AIHA's Bayesian decision analysis test, and what a defensible multi-round assessment actually looks like for a small manufacturer.
Rated CFM is not delivered CFM. How to calculate confined-space blower output at the duct outlet and document it so OSHA cannot call ventilation inadequate.
OSHA's multi-employer policy means the host facility can be cited for contractor chemical training failures. Here's how the four-employer test actually works.