At the beginning of every year, safety and environmental managers scramble to complete reviews of mandatory compliance documentation. Although more frequent
BOB ECKHARDT
At the beginning of every year, safety and environmental managers scramble to complete reviews of mandatory compliance documentation. Although more frequent inspection documentation is necessary for first-aid kits, compressed gas cylinders, cutting and welding equipment, fire extinguishers, and other work equipment, annual review requirements are cited in the following checklist:
In addition, company policies must be revised to reflect five-year record keeping requirements for OSHA 300, 300A, and 301. Injury and illness records, including the OSHA 301 report, must be maintained in a limited-access location available only to the employee and his or her representative.
The start of the new year is a good time to check the status of the OSHA workplace poster (OSHA 3165) as well as posters for hearing conservation regulation, drug and alcohol policy, basic safety rules, workers compensation (provided by the state), plus company-required posters, to verify they are still displayed and legible. The Human Resources Department will also require several posters to be on view in the workplace, including policy statements, minimum wage poster(s), and the medical leave act among others.
| DONE (?) | SUBJECT | REQUIREMENT | REGULATORY REFERENCE |
|---|---|---|---|
| Air permits, exemptions or variances | Should be reviewed annually. Most air permits expire every one to three years and must be renewed either through application, via updated fee submittals, or through annual emissions inventory questionnaires. | State regulation | |
| Bloodborne Pathogen Program | The Exposure Control Plan shall be reviewed and updated at least annually and whenever necessary÷ | 1910.1030 | |
| Confined Space Entry | Review the permit space program÷within one year after each entry and revise the program as necessary÷ | 1910.146 | |
| Cranes, come-alongs (manually operated lever hoists), chain-falls (manual vertical hoists), hoists, slings, hooks, and wire rope. | Not necessarily a written program, but frequent and regular inspections are required and must be documented, in addition to a more detailed annual inspection. Specifics are included in the regulations and the standard. (The California inspection frequency varies from the federal standard.) Inspection forms are useful for this purpose. | 1910.179, 180; 1926.451-.955; Numerous ANSI standards | |
| DOT Accident Log | The annual DOT accident log (no government form) must also be completed and maintained in the event of a DOT audit. | 49 CFR | |
| Electrical | Requirements for inspections can be easily documented with a checklist. Verify inspections were made. | 1910.334; NFPA National Electric Code | |
| Employee Alarm Systems | Test ÷ is made every two months. Be sure to document the test. | 1910.165 | |
| Excavation, Trenching and Shoring | Daily inspections required of the site. An inspection form would be useful here for documentation. | 1926.151 | |
| Fall Arrest Systems | Regular inspections are required for personal fall arrest systems and positioning device systems. | 1926.502 | |
| Fire extinguishers | General Industry. The employer shall assure that portable fire extinguishers are subjected to an annual maintenance check÷12-year hydro static test ÷ and visually inspected monthly. Construction. Portable fire extinguishers shall be inspected periodically ÷ (Use the above general industry criteria.) Stamp or mark cylinder with the hydrostatic test date and keep the inspection card up to date. |
1910.157 1926.150 |
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| Fire, automatic sprinkler systems, fixed systems, standpipe and hose systems | Require your sprinkler system company to inspect and secure copies of the inspection documents. | 1910.37, .158, .159, .160 and numerous ANSI and NFPA requirements | |
| First Aid Kits | Construction industry requirements ÷ first aid kits shall be checked by the employer before being sent out to each job and at least weekly on each job ÷ (Checklist with date and initials maintained in the kit might be easiest.) | 1926.50 | |
| Forklifts | Verify regular inspections are conducted. For additional internal use, verify documentation is available to show the forks have been evaluated for overloading (bending), thickness and integrity with respect to wear on the bottom due to skidding on the concrete floor, and fatigue cracks. | 1910.178 |
2005 MEXICAN LAW CHANGES
According to Glenn McBride in Mexican Laws in English (mexicanlaws.com), the following changes in Mexican laws became effective in 2005:
- New Minimum Wages for 2006 Û The new minimum wages are published every year in December.
- Reforms to the PITEX, Maquila, and PROSEC Decrees, published December 19, 2005
- Reform to Social Security Law, published in DOF on December 14, 2005.
- Law of Acquisitions, Leases, and Services for the Public Sector Û LAASSP reformed June 13, 2003; July 7, 2005.
- Reforms to LGEEPA (The General Law of Ecological Equilibrium and Protection of the Environment), published in DOF on December 7, 2005.