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Fundamental Requirements for Confined Spaces

Originally posted August 19, 2013 by Chris Kilbourne on http://safetydailyadvisor.blr.com

OSHA says that if you allow an employee to enter a permit-required confined space, you must develop and implement a written program for the space.

There is no rule on stacking heights or number of stacks for pallets. However, KY OSHA has a general duty clause statute that says the employer must “furnish to each of his or her employees a place of employment which is free from recognized hazards that are likely to cause death or serious physical harm.” This statement in quotes is used by OSHA inspectors to enforce workplace safety when no specific standard regulates a specific hazard.

If you think that a certain height or number of stacked pallets could potentially cause an accident or injury someone, then the general duty clause applies to you and the stacking is subject to an OSHA citation as if it were a regulated activity. It’s a good idea to establish a written policy with a height/number restriction, so that if OSHA visits you can show that you are controlling the hazard

Are there any regulations or guidelines regarding rack safety? Do you have to post weight limits on the racks, is there required training, etc.?

There are no OSHA regulations specific to racks. However, OSHA has recently fined companies that fail to protect employees from falls and falling object hazards related to racks. Many rack hazards are related to forklifts. OSHA defines a serious violation as a condition for which there is a substantial possibility that death or serious physical harm can result to an employee from a hazard about which the employer knew or should have known.

There are no posting requirements for loads. Training is required for forklift operators in the proper operation of forklifts. Powered industrial truck operator training must cover load manipulation, stacking, and unstacking.

Following is an excerpt from an OSHA interpretation letter concerning pipe racks:

“With regard to an employee working while on an elevated pipe rack, please be advised that we would normally consider such a situation to be in compliance with OSHA fall protection regulations if 1) the employee is protected at all times by an adequate fall arrest system (body belt/harness and lanyard), 2) a safe means of access and egress is provided, and 3) the work can be performed with reasonable ease without a platform. If a platform is needed to safely perform the task, an adequately installed platform, as described in your letter (e.g. a board firmly secured to the top of the pipe or a one inch thick sheet of plywood secured to a layer of pipes), would be acceptable provided 100% fall protection is maintained and proper access and egress are maintained. Please be aware, however, that the effectiveness your system can only be determined by a health and safety professional observing it in actual use under specific circumstances.”

To prevent the most injuries, should a loaded manual pallet jack to be moved more than 20 feet be pushed or pulled by the operator? If pulled, should the operator be facing the pallet or the direction in which they are pulling the jack?

According to OSHA, to prevent injuries, avoid pulling when possible. Pushing generally takes less effort than pulling because your body weight is used to assist the exertion. Also, pulling a load often causes carts to run into the shins or ankles.

Are there regulations or guidelines covering the height for a back rail or guard on a forklift front end attachment?

According to 1910.178(a)(2) Powered Industrial Trucks:

All new powered industrial trucks acquired and used by an employer shall meet the design and construction requirements for powered industrial trucks established in the “American National Standard for Powered Industrial Trucks, Part II, ANSI B56.1,” which is incorporated by reference as specified in 29 CFR 1910.6, except for vehicles intended primarily for earth moving or over-the-road hauling. This consensus standard states the requirements for the load backrest extension if the load presents a hazard.

The forklift manufacturer can tell you if your truck meets the ANSI standard.