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Page 2
What does OSHA mean by a “limited or
restricted means of entry and exit” in the
definition of “confined space”?
Improve
your training
evaluations
As a supervisor it is important for you to understand
what is considered limited or
restricted means of entry and
exit and how it affects your
employees’ safety. OSHA’s
Daily pallet jack
inspection:
Make sure
workers have it
covered!
Page 3
General Industry standard at
29 CFR 1910.146 defines a
confined space as meeting all
of the following criteria:
1.Is large enough for an employee to bodily enter and
work; and
2.Has limited or restricted
means of entry and exit;
and
Alert employees
to the hazards
of winter chores
3.Is not designed for continuous occupancy.
Page 3
If the entrants may freely
step into and out of the space
without having to step over
a raised threshold or stoop
Defining when
forklifts must
be taken out of
service
Page 4
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under the door opening, and
if equipment in the space or
the travelling distance to the
exit could not interfere with
the entrants’ ability to escape
in an emergency, then there
would be no limited means
of entry or exit. If this is the
case, then the space does not
meet the definition of “confined space.”
OSHA’s compliance directive,
CPL 2.100 — Application of
the Permit-Required Confined
Spaces (PRCS) Standards,
includes the following guidance in Section (b) of Appendix E:
Under what circumstances will stairs or ladders
constitute a limited or restricted means of egress
under the standard?
Ladders, and temporary, movable, spiral, or articulated stairs will
usually be considered a limited or restricted means of egress. Fixed
industrial stairs that meet OSHA standards will be considered a
limited or restricted means of egress when the conditions or physical characteristics of the space, in light of the hazards present in it,
would interfere with the entrant’s ability to exit or be rescued in a
hazardous situation.
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See Confined Space, pg. 2
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C O P Y R I G H T J . J . K E L L E R & A S S O C I AT E S , I N C . VO L U M E 1 3 , N U M B E R 1 1 , N OV E M B E R 2 0 1 6
Confined Space, from pg. 1
Does the fact that a space has a door mean that the space does not have limited or
restricted means of entry or exit and, therefore, is not a ‘confined space’?
A space has limited or restricted means of entry or exit if an entrant’s ability to
escape in an emergency would be hindered. The dimensions of a door and its location are factors in determining whether an entrant can easily escape; however, the
presence of a door does not in and of itself mean that the space is not a confined
space. For example, a space such as a bag house or crawl space that has a door leading into it, but also has pipes, conduits, ducts, or equipment or materials that an
employee would be required to crawl over or under or squeeze around in order to
escape, has limited or restricted means of exit. A piece of equipment with an access
door, such as a conveyor feed, a drying oven, or a paint spray enclosure, will also
be considered to have restricted means of entry or exit if an employee has to crawl
to gain access to his or her intended work location. Similarly, an access door or portal which is too small to
allow an employee to walk upright and unimpeded through it will be considered to restrict an employee’s
ability to escape.
What about small openings in a confined space?
A space may be large enough inside for an employee to enter and work, but the portal
to the space may be very small. A confined space (and a permit-required confined
space) must have an entry port that is large enough to allow full-body entry. If the
entrance is too small for a worker to completely enter, or if the space itself is too
small for a worker to completely enter, then OSHA’s confined spaces standard does
not apply. However, that does not mean that the space cannot be hazardous, or that
other OSHA standards do not apply.
Daily pallet jack inspection:
Make sure workers have it covered!
OSHA requires
that all powered industrial
trucks, including motorized
pallet jacks,
be examined
at least daily
before being
placed in service. If the
pallet jack is used on an aroundthe-clock basis, it needs to be
examined after every shift.
While safety or operational deficiencies must be corrected by a
qualified person, it may be the
operator’s responsibility to conduct
a pre-use inspection at the start of
the shift.
The equipment manufacturer’s
safety and maintenance instructions
should be followed.
Some examples of
common inspection items
include:
• Remove unneeded items, tools,
gloves, etc. that could fall off the
equipment
• Look for physical damage
• Check the wheels
• Check for fluid leaks
• Check the battery for damage,
loose or missing cables, visible
leakage, etc.
• Check battery compartment covers and that brackets/retainers
are in place
• Check fork condition
• Ensure hand guard is in good
shape
• Make sure all warning decals
and data plates are legible
• Check gauges
• Make sure control handle moves
smoothly
• Make sure forks raise and lower
properly
• Check speed controls in all
speed ranges
• Test the reverse button or belly
button switch
• Check brakes
• Check emergency/power
disconnect
• Test horn
C O P Y R I G H T J . J . K E L L E R & A S S O C I AT E S , I N C . PAG E 2
N OV E M B E R 2 0 1 6
Improve your training evaluations
According to OSHA’s document,
Resource for Development and
Delivery of Training to Workers
(available at: https://www.osha.
gov/Publications/osha3824.pdf),
there are three types of training
evaluation:
• Training session reaction
assessments,
• Learning assessments, and
• Training impact assessments.
To make sure that the training program is accomplishing its goals,
an evaluation of the training can
be valuable. Training should have,
as one of its critical components,
a method for measuring the effectiveness of the training.
When course objectives and content are developed for a training
program, a plan for
evaluating the training session(s) should
be designed and
integrated into the
program’s other elements. An evaluation
will help employers
or supervisors determine the amount of
learning achieved and
whether a worker’s
performance has
improved on the job.
Among the methods for
evaluating training are:
• Student opinion. Questionnaires
or informal discussions with
workers can help employers
determine the relevance and
appropriateness of the training
program.
• Assessment of student learning. This can be accomplished
through such activities as demonstration skills or testing.
• Supervisors’ observations. Supervisors are in good positions
to observe a worker’s performance, both before and after the
training, and to note improvements or changes.
• Workplace improvements. The
ultimate success of a training program may be changes
throughout the workplace that
result in reduced injury and illness rates.
Alert employees to the hazards of winter chores
From putting up storm windows
and cleaning gutters to hanging
holiday decorations, the work
doesn’t stop when the weather
turns cold.
Always reposition the ladder closer
to the work. Do not over-reach.
Your bellybutton should not go
beyond the sides of the ladder.
Raking leaves and
shoveling snow
Ladder safety
Properly set up the ladder on a
firm, level surface. Never place a
ladder on ground that is slippery or
uneven. Avoid soft, muddy spots.
Make sure the ladder, and the person on it, have plenty of clearance
around electrical wires or other
obstructions.
Remember the 1-to-4 rule: the bottom of the ladder should be one
foot away from the wall for every
four feet of the length of the ladder
from the ground to its top support.
The ladder should extend at least
three feet higher than the roof.
N OV E M B E R 2 0 1 6 Check with your doctor to be sure
you’re healthy enough for this
physical activity. You might be
better off if you hire someone to
remove the leaves or
snow.
Rake or shovel early and
often.
Begin when there is a light covering of leaves or snow so the job
isn’t overly strenuous. Push the
snow. If you must lift, scoop up
small amounts of snow. Remove
deep snow in layers. Do not throw
the leaves or snow over your shoulder or to the side. This twisting
motion stresses your back.
Pace yourself. Warm up
with light exercise. Take
frequent breaks. If you
experience chest pain,
shortness of breath, or
other signs of a heart
attack, seek emergency
care (call 911).
C O P Y R I G H T J . J . K E L L E R & A S S O C I AT E S , I N C .
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Defining when forklifts must be taken out of service
OSHA’s powered industrial truck
standard says that “If at any time a
powered industrial truck is found
to be in need of repair, defective,
or in any way unsafe, the truck
shall be taken out of service until
it has been restored to safe operating condition.” Unfortunately, the
OSHA standard does not define
what exactly is meant by the terms
“in need of repair,” “defective,” and
“unsafe.”
Needing repair or defective
According to OSHA, when determining whether a truck is “in need
of repair,” or “defective,” a variety
of factors are considered. These
factors include, but are not limited
to:
• The condition of the truck itself,
• The manufacturer’s limitations
on the truck, and
• Other safety issues, such as
those considerations found in
consensus standards like ANSI
B56.1.
This requirement is designed to
lessen the frequency of workplace
accidents caused by malfunctioning trucks. Lift trucks are often
involved in accidents because the
truck was not functioning properly.
OSHA says it will consider the
totality of the circumstances surrounding a powered industrial truck
in determining whether it is “in
need of repair” or “defective.”
Unsafe
“Unsafe,” as used in the standard,
carries the general meaning of presenting a harm or risk. For example, all gauges must be functioning
properly. Should a gauge not be
functioning properly, the truck
would usually be considered defective and in need of repair, thereby
making the truck unsafe.
Other indications of vehicle neglect
are leaky hydraulic systems, kinked
or collapsed hydraulic hoses, missing bolts, damage to the overhead
guard, tires with large pieces missing, and leaking fuel systems. All
of these conditions would make the
truck unsafe.
Be aware that there are times an
equipment defect may go unreported because the operator knows
how to “circumvent” the problem
(i.e., if the operator knows he/she
has to pump the brakes three times
before the brakes begin to work,
why report the defect?)
Repair
Because of the danger that malfunctioning lift trucks present, it is
required that only properly trained
and authorized personnel repair lift
trucks.
The standard does not require that
all forklift repairs be made by an
authorized service technician from
the selling dealership, but it does
require that whoever does perform
the repair is knowledgeable of the
particular area being serviced. Letting an authorized dealer’s service
technician perform lift truck repairs
and routine checks is one way to
assure that the correct repair parts
are installed and that correct repair
procedures are followed.
Copyright 2016 J. J. Keller & Associates, Inc.
Neither the Supervisor Safety Alert nor any part thereof may be reproduced without the written permission of J. J. Keller.
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associated with omissions, errors, or misprintings in this publication. This publication is designed to provide reasonably
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DIRECTOR OF EDITORIAL RESOURCES: Paul V. Arnold
EDITOR: Michelle M. Graveen
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