General Environmental Controls

Under 1910.147(f)(1), an employer may temporarily remove lockout/tagout devices and re-energize equipment only when testing or positioning is necessary; this must follow a specific sequence and provide employee protection. Employers must: clear tools and materials from the machine, remove employees from the danger area, remove LOTO devices as specified, energize only for the short time needed while maintaining effective protections, then de-energize and reapply LOTO if additional servicing is required. See 1910.147(f)(1) and OSHA's interpretation on the minor servicing exception for the required sequence and protections at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.

When testing or positioning requires energization, the employer must implement a written procedure that follows the steps in 1910.147(f)(1): clear the machine, remove employees from the hazard area, remove LOTO devices as allowed, energize briefly with effective employee protection, then de-energize and reapply LOTO if further servicing is needed. The protections must prevent exposure during the energized period. See 1910.147 and OSHA’s interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.

No. OSHA does not automatically accept the ANSI definitions of “alternative methods” as substitutes for the requirements of 1910.147. Employers may use consensus standards for guidance, but OSHA requires compliance with the procedures and protections in 1910.147 unless the standard specifically permits an alternative. See 1910.147 and OSHA’s response on ANSI alternatives at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.

No. Temporary removal to jog or inch a machine is allowed only under the controlled sequence in 1910.147(f)(1) and only when necessary for testing or positioning; employers must also provide effective employee protection during the energized interval (for example, guarding or removing employees from the danger area). See 1910.147 and the minor servicing interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.

Under 1910.147, employers must train authorized, affected, and other employees about the energy control program so each employee understands their role: authorized employees receive training in recognition of hazardous energy sources and application of energy control procedures; affected employees are instructed on the purpose and use; and other employees are made aware of the prohibition against attempting to restart machines under LOTO. Retraining is required when procedures change or when there is reason to believe an employee’s knowledge is inadequate. See 1910.147.

Under 1910.147(c)(6), employers must perform annual periodic inspections of each energy control procedure to ensure the procedure and the employer's practices are being followed. The inspection must be conducted by an authorized employee other than the one(s) using the procedure, and it must identify any deviations or inadequacies and correct them. See 1910.147(c)(6).

Under 1910.147, tagout may be used only where the employer can demonstrate that the energy-isolating device cannot be locked and that the tag system provides equivalent protection; otherwise, lockout is required. Tags are warning devices that do not provide the physical restraint of a lock and require additional measures to ensure safety. See 1910.147 for tagout limitations and required supplemental protections.

Under 1910.146, a permit-required confined space (PRCS) is a confined space that has one or more of the following hazards: a hazardous atmosphere, a material that can engulf an entrant, an internal configuration that could trap or asphyxiate, or any other recognized serious safety or health hazard. Employers must evaluate their spaces and treat those meeting the definition as PRCS. See 1910.146.

Under 1910.146(c)(5), a permit must document pre-entry measures and conditions (e.g., atmospheric tests, isolation steps, ventilation, PPE, rescue arrangements) and be signed/authorized before entry. A permit is valid only for the duration specified on it and must be canceled and a new permit issued if conditions change or the allotted time expires. Employers must retain cancelled permits for at least 1 year. See 1910.146(c)(5).

Under 1910.146(d), the attendant must remain outside the permit space for the duration of entry, monitor entrants, perform non-entry rescue communications and procedures, order evacuations if needed, and keep unauthorized persons away. The attendant also must be trained to recognize hazards and use emergency procedures. See 1910.146(d).

Under 1910.146(k), employers must arrange for prompt rescue and emergency services, either by in-house teams trained and equipped for rescue or by contract with local rescue providers. Rescue personnel must be trained and available, and employers must ensure timely response and appropriate equipment (including atmospheric monitoring and retrieval systems) for entrants in permit spaces. See 1910.146(k).

Under 1910.146(j), employers may use alternative procedures (e.g., continuous forced air ventilation to eliminate hazardous atmosphere) only when the space has only an atmospheric hazard and the employer can demonstrate that the measures maintain safe conditions during entry. The employer must meet all requirements listed in 1910.146(j) and reassess the space if conditions change. See 1910.146(j).

Under 1910.146(g), the host employer must inform contractors about known hazards, provide the employer’s permit space program, coordinate entry operations, and ensure contractors comply with permit requirements. The employer controlling the site must maintain oversight and share permit and hazard information so entrants and rescue providers are protected. See 1910.146(g).

Under 1910.141, employers must provide potable drinking water and sanitary facilities, including adequate handwashing facilities where employee hygiene requires them. Drinking water must be safe and readily accessible, and employers must maintain cleanliness of sanitary and handwashing areas. See 1910.141.

Under 1910.141(c), employers must provide toilet facilities in sufficient numbers based on the number of employees and gender distribution; the standards specify minimum ratios and require facilities to be cleaned and sanitary. Employers should consult the specific tables and provisions in 1910.141 to determine exact counts for their workforce size and situation.

Under 1910.145, safety signs and tags must use standardized signal words, colors, and formats to communicate hazards; they should be legible, visible, and convey the nature of the hazard and the necessary action. Employers must follow the sign and tag criteria in 1910.145 when selecting or designing workplace signs and tags.

Under 1910.145, use 'DANGER' signs for immediate hazards that will cause death or serious injury, 'WARNING' for hazards that could cause death or serious injury, and 'CAUTION' for less severe hazards. Employers should select the appropriate signal word and color scheme per 1910.145 to match the level of risk.

Under Subpart J and related provisions, employers must control airborne contaminants and provide adequate ventilation or local exhaust when necessary to protect employee health, such as to maintain safe atmospheric conditions in confined spaces or to reduce exposures to hazardous substances. Specific requirements may be triggered by the hazard, and employers should follow the applicable sections like 1910.146 for confined space ventilation and general industry standards for contaminant control in 1910.

For civilian employees covered by OSHA, employers must follow the Respiratory Protection Standard’s definition that an oxygen-deficient atmosphere is below 19.5% oxygen by volume, and treat such atmospheres as immediately dangerous to life or health (IDLH) unless an employer demonstrates otherwise under the table allowances. This applies where OSHA has jurisdiction over civilian workers, including some federal workplaces. See the OSHA interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16 and the Respiratory Protection Standard in 1910.

Yes. Storing pre-charged air conditioners or heat pumps containing Category 1 flammable refrigerants onsite in aggregated quantities at one location that meet or exceed the 10,000 pound threshold can make that storage a PSM-covered process under 1910.119 because storage and on-site movement are part of a "process." See OSHA’s interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06 and the general OSHA standards at 1910.

If crane operators face the potential for head injury from falling objects or overhead hazards (for example, lifting loads overhead), the employer must provide and require protective helmets that meet the ANSI helmet standards incorporated in [1910.135]. The employer must assess hazards per [1910.132(d)(1)] and require helmets where necessary. See 1910.135 and OSHA’s interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2.

Mobile ladder stands and platforms must have a step width of at least 16 inches, steps uniformly spaced with rise not more than 10 inches and depth not less than 7 inches, and a step stringer slope not more than 60 degrees; handrails and midrails are required for platform heights of 4 to 10 feet, and guardrails/toeboards above 10 feet. See 1910.23(e) and OSHA’s interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0.

No. OSHA does not specifically require fall protection for the simple act of stepping from a portable ladder onto a low-slope roof and walking to a work area 25 feet from the roof edge; however, fall protection may be required for the actual work depending on distance to edge and whether the work is frequent or permanent. Employers should review the criteria in the fall protection rules for work performed within 6 feet of an edge, and for work 15 feet or more from the edge consider whether the task is infrequent/temporary as explained in OSHA’s interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-1 and general requirements in 1910.

Handrails are not considered vertical barriers for measuring standard stair width; the required minimum width (22 inches for standard stairs) is measured between vertical barriers such as walls or guardrails, not between handrails. See the stair width guidance in OSHA’s stair interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-17 and the relevant stairway provisions in 1910.

Yes. OSHA recognizes that C-type light truck tires may be treated similarly to LT tires for servicing requirements; failure to comply with 1910.177 for servicing pickup truck and van tires using C-type tires may be considered de minimis depending on facts. Employers should follow 1910.177 servicing rules and consult the interpretation for details. See OSHA’s rim wheel interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01 and 1910.

No. As of February 5, 2025, OSHA announced an enforcement stay and will not enforce the COVID-19 recordkeeping and reporting requirements under 29 CFR 1910.502, including maintenance of a COVID-19 log and reporting COVID-19 fatalities and hospitalizations; OSHA will continue to enforce other recordkeeping requirements under 29 CFR part 1904. See OSHA’s memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05.

If energized testing or positioning shows additional servicing is needed, the authorized employee must de-energize the machine, isolate it from its energy source, and reapply lockout/tagout devices according to the energy control procedure before proceeding. The temporary energized condition is only allowed for the time necessary to test or position. See 1910.147(f)(1) and OSHA’s interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.