News & Information Blog

To start with, OSHA is covered by Title 29 and the enforcement language is called the Code of Federal Regulations. The standards are separated by Parts. Here are the ones that we see most often:

• Part 1904, the Recordkeeping standards for occupational injury/illnesses
• Part 1910, the General Industry standards
• Part 1926, the Construction standard

Subparts break the standards up into similar groups.

• Subpart D, Walking/Working Surfaces
• Subpart E, Means of Egress
• Subpart G, Occupational Health and Environmental Control
• Subpart H, Hazardous Materials
• Subpart I, Personal Protective Equipment (PPE)
• 1910 Subpart J - General Environmental Controls
• Subpart K, Medical and First Aid 
• Subpart L, Fire Protection
• Subpart N, Materials Handling and Storage 
• Subpart O, Machinery and Machine Guarding
• Subpart P, Hand and Portable Powered Tools
• Subpart Q, Welding, Cutting, and Brazing

And so on down to Subpart Z, Toxic and Hazardous Substances.

The Subparts are broken down into Sections. The Part and the Section are what we are used to seeing. The number to the left of the decimal is the part. The number to the right of the decimal is the section. For example, Subpart G is broken down into Section 94 for the Ventilation standard, 1910.94, Section 95 for the Occupational Noise standard, 1910.95, and Section 97 for the Nonionizing radiation standard, 1910.97.

Within the Ventilation standard the requirements are broken down into sections related to what is generating the need for ventilation. For example (a) is for Abrasive Blasting, (b) is for Grinding, polishing, and buffing operations this takes the place of Scope for the whole standard.

It’s easier when they actually say "Scope" as in the Walking Working Surfaces standard, 1910.21, which states in paragraph (a) "Scope. This subpart applies to all general industry workplaces. It covers all walking-working surfaces unless specifically excluded by an individual section of this subpart." Or 'Scope, 1910 applies to all general industry workplaces. 1910 covers all walking-working surfaces unless specifically excluded by an individual section (what we would call a standard such as 1910.21) of 1910.' 

So, if there you are covered under the General Industry Part and Subpart of a section (standard) that has requirements for a walking or working surface that requirement trumps 1910.21. And, if you are written up for a violation of 1910.21 when you are complying with a standard with specific walking or working surfaces requirements that violation does not apply.

I am hoping that you are beginning to understand how important it is to know which standards apply to your workplace conditions and which do not. Let me provide you with and example from my enforcement days.

Because Wisconsin Public Sector "OSHA" enforcement is almost exactly like OSHA Consultation I tended to work with the smaller municipalities who could not afford a consultant or a full time, experienced Safety Manager. I was on a first visit with a small village, three employees, and running through my 'getting to know you' checklist. They had a full Permit Required Confined Space Entry Program. 

I asked them a few questions about permit requirements that are usually overlooked and found they had an excellent Confined Space Entry Program. They showed me their 3-ring binder of spaces, complete with pictures and entry procedures. As well as documentation that the nearest Fire Department had practiced emergency body removal procedures.

As I read through and asked questions, I found they had spent over $5,000 of the village's meager budget to come into compliance with 1910.146, Permit Required Confined Space standard. The binder and pictures had been created for them by a Consultant who had also done their training. 

For each confined space I asked them to describe the hazard. No space had a hazard or even potential to create a hazard, therefore they had not confined spaces that met the scope of the standard, which is the first sentence:

"Scope and application. This section contains requirements for practices and procedures to protect employees in general industry from the hazards of entry into permit-required confined spaces."

Had they read and understood the sentence of the standard they could have saved themselves $5,000, probably a good chunk of the village's yearly budget.

If you have any questions from our blogs, or anything else, please contact us, we would love to geek out about safety with you!! There is always more to learn!