What Employers Should Note about OSHA's Phase 4

Nilan Johnson Lewis PA

OSHA’s Standard Improvements Project Rule (Phase IV) was published in the May 14 Federal Register and is intended to remove or revise “outdated, duplicative, unnecessary and inconsistent requirements” in the agency’s safety and health standards.  This is the fourth review of this ongoing effort.  The goal is to “reduce regulatory burden while maintaining or enhancing worker safety and health and improving privacy protections.”

The Rule will become effective on July 15, 2019.

These standard revisions cross all industries. Some are merely clarifications and do not require changes in practice. Others are aimed at streamlining processes and reducing paperwork. However, there are some with precise and highly technical revisions that could affect your business.  Employers should identify which changes relate to their industry and operations and alert their safety team members to the new rules.  Please click here to see the final rule.

Key Points Employers Should Note about the Final Rule

  • An update to the consensus standard incorporated by reference for signs and devices used to protect workers near automobile traffic,
  • A revision to the requirements for roll-over protective structures to comply with current consensus standards,
  • Updates for storage of digital x-rays,
  • An exclusion of feral cats as vermin that need to be controlled in shipyards,
  • A reduction of the minimum breaking strength requirement for lifelines,
  • Revision of two standards to align with current medical practice: a reduction to the number of necessary employee x-rays and updates to requirements for pulmonary function testing.
  • An update to the method of calling emergency services to allow for the use of current technology, and
  • Removal of the requirement that employers include an employee’s social security number (SSN) on exposure monitoring, medical surveillance, and other records.

OSHA is NOT moving forward with proposed revisions to the lockout/tagout general industry standard, personal protective equipment fit in construction, the excavation construction standard, or the decompression tables in the underground construction standard.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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