Am I a for-hire carrier?

What's an environmental compliance review?

An environmental compliance review is a structured evaluation of how a proposed change could affect a facility's environmental obligations.

Many organizations incorporate environmental reviews into an environmental management system (EMS) or formal change-management process. These procedures help ensure that environmental obligations are evaluated before operational changes are implemented. The updated ISO 14001 standard places greater emphasis on managing changes that may affect environmental performance, reinforcing the need to assess environmental impacts before decisions are made.

The review doesn't need to be complicated. In many cases, it involves determining whether the change could affect air permits, wastewater discharges, stormwater permits, hazardous waste management, chemical reporting, spill prevention requirements, or other environmental programs.

The goal is to identify environmental impacts before a change is implemented rather than after a regulator, auditor, or inspector discovers a problem.

Production increases

Increasing production is often viewed as a business decision rather than an environmental one. However, greater production may increase air emissions, wastewater generation, chemical usage, and waste generation.

Facilities should evaluate whether higher throughput could affect permit limits, reporting thresholds, or compliance obligations before production levels increase.

New chemicals or raw materials

A new chemical can trigger a wide range of environmental requirements.

Changes in raw materials may affect hazardous waste determinations, emergency planning requirements, air emissions calculations, Toxics Release Inventory reporting, spill prevention planning, or wastewater characteristics.

Before purchasing or introducing a new chemical, facilities should evaluate its environmental implications and ensure required controls are in place.

Equipment replacements and upgrades

Many organizations assume replacing equipment is simply a maintenance activity. In reality, equipment changes can have environmental consequences.

Replacing a boiler, coating operation, storage tank, dust collector, scrubber, or process equipment may affect emissions, waste streams, monitoring requirements, or permit applicability. Even when equipment serves the same function, environmental impacts should be evaluated before installation.

Process modifications

Changing how a product is manufactured can create environmental consequences even when production levels stay the same.

New process steps, altered operating conditions, different fuels, or modified treatment systems can affect emissions, waste generation, water usage, and permit conditions. Process changes should be reviewed to determine whether existing permits and operating procedures remain appropriate.

Facility expansions

Building additions, new production lines, warehouse expansions, and site development projects often involve environmental considerations beyond construction activities.

Organizations should evaluate potential impacts on air permits, stormwater management, wastewater infrastructure, storage capacity, and environmental monitoring programs before expansion projects begin.

Changes in waste management practices

Facilities occasionally change waste vendors, storage practices, recycling programs, treatment methods, or waste handling procedures to improve efficiency or reduce costs.

While these changes may appear administrative, they can affect generator status, accumulation practices, recordkeeping obligations, and waste determinations. Environmental personnel should review proposed changes before implementation.

New products or services

New products often require new materials, equipment, or processes that may affect existing environmental obligations.

Contractor activities

Contractor activities involving chemicals, waste management, tank cleaning, painting, excavation, demolition, or maintenance may create environmental compliance implications that warrant review.

Property and infrastructure changes

Changes to storage areas, containment systems, drainage patterns, tanks, or utilities can affect stormwater exposure and other environmental obligations.

Acquisitions and ownership changes

Acquiring a facility or business can introduce new permits, reporting obligations, and compliance responsibilities that should be evaluated during due diligence.

Train employees to recognize when a review may be needed

Environmental departments cannot review changes they never hear about.

Engineering, maintenance, operations, purchasing, project management, and production personnel are often the first to learn about proposed changes. Providing basic awareness training can help these groups recognize situations that may have environmental implications.

Employees don't need to become environmental experts. Instead, they should know when to notify EHS and ask whether a compliance review is warranted. A simple "check with EHS before proceeding" expectation can prevent significant compliance problems and reduce the likelihood that environmental requirements will be discovered too late.

Key to remember: Many environmental compliance issues begin with an operational change. Establishing a process to identify and review changes before implementation can help organizations avoid permit problems, reporting errors, and unexpected regulatory obligations.

Used oil management starts in the shop

Many maintenance departments generate used oil from equipment servicing, vehicle maintenance, and hydraulic system repairs. While used oil can often be managed under streamlined regulations, improper handling can quickly create compliance problems.

Common issues include storing used oil in unlabeled containers, mixing used oil with hazardous waste, and failing to address leaks from storage containers. Even small mistakes can increase disposal costs or change how the waste must be managed.

Maintenance personnel can help reduce these risks by ensuring used oil containers remain closed when not in use, are properly labeled, and are routinely inspected for signs of leakage or deterioration.

Spill response depends on employees closest to the release

When a spill occurs, maintenance staff members are often among the first employees on scene.

Their actions during the first few minutes can affect both environmental impacts and regulatory obligations. Quickly stopping the source of a release, protecting drains, and containing spilled material can prevent a minor incident from becoming a reportable event.

Facilities should ensure maintenance personnel understand spill response procedures, know where response equipment is located, and recognize when environmental staff or emergency responders must be notified.

Even facilities with formal spill response plans depend on maintenance employees to implement many of the initial response actions.

Air compliance requires reliable equipment

Many facilities rely on air pollution control devices such as baghouses, scrubbers, thermal oxidizers, and dust collection systems to comply with permit requirements.

Environmental managers may be responsible for reporting emissions and maintaining permit records, but maintenance staff members are often responsible for keeping control equipment operating properly.

A failed pressure gauge, malfunctioning fan, broken duct connection, or neglected preventive maintenance task can affect emissions performance and potentially result in permit deviations.

Facilities should ensure maintenance programs include environmental control equipment and that maintenance personnel understand which equipment has environmental significance.

Tanks and containment need routine attention

Storage tanks and secondary containment systems are another area where maintenance and environmental responsibilities overlap.

Maintenance personnel may also maintain stormwater controls, drainage structures, and outdoor storage areas that affect permit compliance.

Routine inspections can identify corrosion, damaged coatings, leaking fittings, deteriorated hoses, and cracks before they become larger problems. These conditions may not seem urgent from an operational perspective, but they can increase the risk of releases and regulatory violations.

Facilities should establish inspection procedures, clearly define responsibilities, and document findings. A simple inspection program can often identify problems early, reducing both environmental risk and repair costs.

Communication helps prevent violations

Many environmental compliance issues occur when operational changes are made without considering environmental impacts.

New equipment, replacement tanks, process modifications, and maintenance projects can affect air emissions, waste generation, chemical storage, and spill prevention requirements. Environmental staff may not become aware of these changes until after installation.

Regular communication between maintenance and environmental personnel can help identify potential compliance concerns before work begins. In many cases, a short conversation during project planning can prevent significant compliance challenges later.

Building a partnership between maintenance and environmental teams

Environmental compliance is most effective when it's integrated into daily operations. Maintenance teams often have the best understanding of equipment conditions, storage systems, and operational changes occurring throughout a facility.

Environmental awareness training, maintenance involvement in inspections, and regular communication can strengthen compliance programs and identify problems sooner.

Environmental managers bring regulatory expertise. Maintenance personnel bring operational knowledge. Together, they create a stronger foundation for compliance than either group can achieve alone.

Key to remember: Environmental compliance isn't solely an EHS responsibility. Maintenance staff members play a critical role in preventing spills, managing used oil, maintaining compliance equipment, and identifying problems before they become violations.

Running in circles or reducing incidents?

Believe it or not, roundabouts aren’t just there to make you question your sense of direction, make your GPS recalculate for the fifth time, or give your Uncle Bob another conspiracy theory to support. These circular marvels are actually traffic safety ninjas.

Studies by the Federal Highway Administration (FHWA) have shown that roundabouts typically result in:

How to maneuver the roundabout

Don’t let these circular conundrums make drivers question everything you thought they knew about right-of-way, geometry, and your own patience. Here what to know so you can manage roundabouts without the road rage:

• Counterclockwise travel — Traffic travels counterclockwise around the center island. (In other words, spin around to the right.) Drivers should choose the lane where they want to go after the roundabout since there’s not much time to shift gears (or lanes).
• Entry yields control — Vehicles entering the roundabout yield to traffic already circulating. (In other words, whoever is in the circle first has the right-of-way.) Drivers must yield to traffic in all lanes of the roundabout, not just in the lane closest to them, and allow room for larger vehicles like semis or those pulling trailers.
• Don’t stop if you don’t have to — The entrance to the roundabout is a “yield” rather than a “stop.” (In other words, plan ahead so you can enter seamlessly into the circle so the confident roundabout renegade behind you doesn’t join you in your back seat!)
• Low speed — The curvature of the roundabout requires slower vehicle speeds (15-25 mph) throughout the roundabout. (In other words, slow down!)
• No power necessary — Unlike traffic signals, roundabouts are not susceptible to power failures to keep a tab on traffic chaos.

Think of navigating a roundabout like you are joining a polite game of bumper cars — everyone’s circling, and nobody’s crashing. You enter and exit only when you’ve proven you know how to yield without panicking (or making eye contact). Until then, you can always ask Siri how to avoid them altogether, but you may want to leave the house earlier!

Where the idea originated

For the critical thinkers who like to know where this concept of avoiding vertigo on the way to the office originated, here’s a historical detour to see that the idea isn’t new. Roundabouts have been a concept since an 18th century inventor called Pierre L’Enfant designed what became known as “traffic circles” in Washington DC.

The traffic trickery became part of the transportation system in 1905, when the Columbus Circle opened in New York City—one of the first traffic circles designed for cars. We have William Phelps Eno to thank (or criticize, depending upon your opinion of roundabouts) for that. The first European roundabout was built in 1907 in Letchworth Garden City, England — not for traffic, but as a pedestrian island. So yes, the early roundabouts weren’t even meant for cars, which might explain why some drivers still treat them like mysterious crop circles.

Improvements were made in the UK in the 1960’s to help prevent circular intersections from locking up, by not allowing vehicles to enter the intersection until there were enough gaps in circulating traffic. In addition, smaller circular intersections were proposed to not just fit the geography but that made vehicles turn more tightly, resulting in slower entry and circulating speeds.

The modern roundabout has greatly improved in terms of operations and safety, when compared with older roadway rotaries. The benefits of which include:

• Promoting lower speeds and traffic calming which reduces incidents;
• Reducing conflict points and traffic back-ups which improves traffic flow and reduces driver anxiety and frustration;
• Improving vehicle operational performance (e.g., gas conservation, reducing engine overheating, etc.); and
• Meeting a wide range of traffic conditions with versatility in size, shape, and design.

These obnoxious orbs are popping up everywhere across the U.S. and Canada, but now you are prepared to circle in style!

Key to remember: Roundabouts aren’t just a fancy way to make you feel like a NASCAR driver. Once you crack the circular code, you may just embrace these engineering superheroes for their ability to not only reduce traffic jams and fender benders but save lives!

DOT’s actions

Along with removing over 28,000 unqualified drivers from roadways, canceling 30,000 illegally issued licenses, and removing over 8,000 unqualified training schools from the Entry-Level Driver Training (ELDT) Training Provider Registry (TPR) over the past year and half, the DOT’s most recent steps toward enforcing greater safety and less fraud include:

• “The Emergency Removal of Training Providers,” which involves removing over 110 ELDT providers from the TPR due to not meeting the English Language Proficiency requirements;
• “Performing Targeted Investigations and Proposing Removals,” which involved non-compliance in terms of training driving space, instructors, documentation, and classroom location; and
• “Conducting a Nationwide Audit of Third-Party Skills Testers,” which involves holding states accountable for failing to compliantly authorize third-party testers.

DHS’s actions

The DHS has begun a criminal investigation across the commercial driver’s license (CDL) and commercial trucking spaces to identify fraud, financial crimes, exploitation, and potential human/drug trafficking activities, including:

• A synchronized investigation at over 200 CDL-related schools, carriers, employers, and businesses;
• Publicizing over 1,000 CDL-related leads from companies suspected of transportation-related offenses;
• Investigations concerning fraudulent and unauthorized activities related to CDL fraud, unauthorized employment, and fraudulent medical certification.

DOJ’s actions

The DOJ announced its upcoming creation of the Joint Task Force Crossroads of America, which will:

• Protect U.S. borders and roadways to reduce fatalities, injuries, and criminal activity;
• Team up U.S Attorney’s Offices in IL, IN, MI, and OH with state police and federal partners.

FMCSA guidance

1. DQ files - An acquiring carrier does not have to create a new DQ file for drivers when:

• The acquired company deactivates their United States Department of Transportation (USDOT) number and Federal Employer Identification Number (FEIN), and
• There is no break in employment for the drivers.

“No break in employment” means that the acquired company’s drivers did not have to reapply for their job.

Best Practice: To avoid confusion during an FMCSA audit, put a note in each file showing that the driver files were part of an acquisition, along with the date the drivers started working for the acquiring company.

2. Clearinghouse queries - There is no need to run a pre-employment Drug and Alcohol Clearinghouse query for the acquired company’s commercial driver’s license (CDL) drivers if there is no break in employment. However, an annual query must be run within one year of the last query while at the acquired company. The dates of the prior annual query may be a different date for each driver, which is not easy to track.

Best Practice: Run the annual query on the new drivers before they operate a commercial motor vehicle (CMV) requiring a commercial driver’s license (CDL) for the acquiring company. This query is to verify that no driver is in a “Prohibited” status due to a positive test and missing a negative return-to-duty test. The query also resets the next annual query date to a known day a year in advance for each driver.

What are the risks of not creating new DQ files?

The acquiring company owns all errors and omissions in a DQ file. If, for any reason, a driver is not fully qualified and all documents are not current, the acquiring carrier is responsible.

Suppose serious violations on a new driver’s motor vehicle record (MVR) do not meet the company’s hiring criteria. If an MVR wasn’t run as is normally required for new-hire DQ files, a plaintiff’s attorney may accuse the acquiring company of negligent hiring in post-crash litigation.

Best practices:

• Audit each file for compliance gaps as part of the acquisition process.
• Document violations along with remedial actions, if any.
• Review the MVR and any other performance history available for each driver.

If documents are missing or incorrect, the acquiring carrier would still be subject to a violation if audited by FMCSA. Acknowledging errors and documenting “meaningful action” could mitigate penalties.

Keys to remember: Audit the DQ files of an acquired company’s drivers and document compliance issues and remedial actions. Also, run an annual query to detect drivers prohibited from driving a CMV.

What is the NSC?

In 1987, the federal, provincial, and territorial Ministers responsible for Transportation and Highway Safety recognized that due to the deregulation of transportation, there was a need for harmonization and reciprocity in the management of commercial vehicles across Canada. The ministers then signed a memorandum of understanding to develop and implement the NSC to encourage road safety, promote efficiency in the motor carrier industry, and achieve consistent safety standards. The National Safety Code standards remain important instruments of public policy in promoting public safety and the safe and efficient movement of people and goods on Canadian roads.

What are the 16 standards?

The NSC is a set of minimum performance standards, applying to all persons responsible for the safe operation of commercial vehicles. There are 16 NSC standards made up of the following:

• Standard 1 Single Driver Licence Concept
• Standard 2 Knowledge and Performance Tests (Drivers)
• Standard 3 Driver Examiner Training Program
• Standard 4 Driver Licencing Classification
• Standard 5 Self-Certification Standards and Procedures
• Standard 6 Determining Driver Fitness in Canada
• Standard 7 Carrier and Driver Profiles
• Standard 8 Short-Term Suspension
• Standard 9 Commercial Vehicle Drivers Hours of Service
• Standard 10 Cargo Securement
• Standard 11 Maintenance and Periodic Inspection
• Standard 12 CVSA On-Road Inspection
• Standard 13 Trip Inspection
• Standard 14 Safety Rating
• Standard 15 Facility Audits
• Standard 16 Entry Level Training (Class 1)

Now that we have a better understanding of what the NSC represents and what the 16 standards are, let’s take a deeper dive into the standards that apply, starting with Motor Carriers.

NSC Standard 14 — Safety Rating

You might be wondering why we are starting with Standard 14. All provinces in Canada are required to issue an NSC number to all commercial carriers in their governing jurisdiction. A Safety Fitness Certificate (SFC) contains the NSC number, which is the unique identifier for each commercial operator. Ontario calls this number a Commercial Vehicle Operator’s Registration or CVOR.

If you have registered a vehicle that is regulated under the National Safety Code program in Canada, you are required to apply for a SFC or CVOR (Ontario). The SFC or CVOR gives you permission to operate a commercial vehicle.

There have been many new changes recently to the process of not only applying for an SFC but also in maintaining the required certificate. For example, in Alberta, it includes completing an NSC knowledge test online or NSC in a registry office, completing an NSC audit within 12 months of obtaining your SFC, and renewing your certificate every three years.

A provincial authority may not issue a safety fitness certificate to an extra-provincial motor carrier undertaking unless the provincial authority has determined that the undertaking has a “satisfactory”, “satisfactory unaudited” or “conditional” safety rating, as set out in section 5 of Part C of NSC Standard #14.

Safety Rating Categories

Responsibility for motor carrier safety resides, first and foremost, with motor carrier management. The Safety Rating Standard (Standard 14) establishes the motor carrier safety rating framework by which each jurisdiction shall assess the safety performance of motor carriers. There are four safety rating categories as follows:

• Using the information in the motor carrier profile;
• Assigning a value to each of the data listed in the motor carrier profile taking into account its severity and potential safety impact, in accordance with the National Safety Code Standard 7, Carrier Profile:
  • For the 24 months preceding the determination; or
  • In the case of a motor carrier whose motor carrier profile was established less than 24 months prior to the determination, for the period since its establishment;
• Normalizing the weighted data using the motor carrier’s fleet size to reflect the motor carrier’s exposure to risk; and
• Assigning a safety rating to the motor carrier in accordance with the safety rating categories.

The NSC’s safety fitness rests on three building blocks:

• NSC Standard 7: Carrier and Driver Profiles
• NSC Standard 14: Safety Rating
• NSC Standard 15: Facility Audit

Together, these standards provide the safety rating and management framework by which each jurisdiction assesses the safety performance of motor carriers. In part 3, we’ll cover Standards 7 and 15 in greater detail.

Key to remember: We have just touched the surface of the NSC standards and covered likely one of the most important when it comes to maintaining a safe rating and compliance with Jurisdictional regulations.

What happened?

The EEOC’s suit charged that the company intentionally violated federal law by engaging in a long-standing pattern of refusing to hire female laborers at one of its plants. This potentially impacted thousands of women, according to the EEOC.

Hiring compliance problems allegedly began in 2006 when the company purchased the plant. Through late 2022, the company intentionally hired only men for laborer positions and converted showers and locker rooms to male-only facilities.

When the company began outsourcing its labor staffing to third-party agencies, it directed them to refer only male applicants even when qualified female candidates were available.

The lawsuit also alleged that the company’s discriminatory practices continued even after the EEOC investigated a whistleblower complaint made by a long-tenured employee who was terminated for telling the truth about its hiring practice. The EEOC previously settled the whistleblower’s retaliation case for $90,000.

More than just a fine

Under the 3-year consent decree resolving the lawsuit, the company will not only pay $2.6 million in monetary damages to compensate women who were denied employment, it must also:

• Hire a Title VII coordinator
• Provide mandatory anti-discrimination training to its managers and employees
• Notify all staffing agencies it works with not to comply with any discriminatory requests, and
• Post a notice to employees about the settlement and how to report any future discrimination.

Staffing agencies dinged, too

The EEOC also fined the two staffing agencies that went along with the company’s illegal hiring scheme. Although the fines were substantially lower for the agencies, chances are they’re on the EEOC’s radar now, as well.

‘Why can’t we just hire men?’

This might’ve been the question company leaders asked prior to the EEOC lawsuit. And, in RARE cases an employer can consider sex when hiring. Sex can be considered where it’s a bona fide requirement. For example, an employer looking to hire models for women’s clothing wouldn’t need to consider male applicants.

But for anyone wondering why the recycling plant couldn’t only hire men, here’s the reason:

Title VII of the Civil Rights Act of 1964 is a federal law enforced by the EEOC. The law prohibits employment discrimination based on protected characteristics, like:

• Race
• Color
• Religion
• Sex
• National origin

Title VII says it’s illegal to discriminate based on protected categories (like sex) in any aspect of employment, like:

• Hiring and firing;
• Compensation, assignment, or classification of employees;
• Transfer, promotion, layoff, or recall;
• Job advertisements;
• Recruitment;
• Testing;
• Use of company facilities;
• Training and apprenticeship programs;
• Fringe benefits;
• Pay, retirement plans, and disability leave; or
• Other terms and conditions of employment.

While that’s a long list of rules, it’s a lot easier to digest than a $2.6 million fine.

Key to remember: Costly lessons in a hiring discrimination case can be a “don’t do what we did” moment for other employers wondering why they can’t hire only men.

When hazards often begin

One challenge with abrasive wheel machines is that hazards can develop while the machine still appears to operate normally. The grinder turns on, the wheel spins, and employees continue working or adapt to deficiencies because no injury has occurred, creating a false sense of security.

Abrasive wheel machines are common, familiar, and often used for short tasks such as sharpening tools, smoothing rough edges, removing burrs, or preparing materials for production. Conditions that seem minor on the surface can expose employees to serious struck-by, contact, and fragmentation hazards. Common abrasive wheel machine hazards include:

• Contact with the rotating wheel,
• Flying sparks and debris,
• Wheel breakage or fragmentation,
• Material being pulled between the wheel and support surfaces,
• Improper wheel installation, and
• Inadequate eye and face protection.

What OSHA frequently evaluates

OSHA looks at whether the machine’s safeguards are in place, properly adjusted, and maintained to protect employees during use. As wheels wear down, the relationship between the wheel, work rest, and tongue guard changes with it. These changes happen a little at a time, they can be easy to miss during day-to-day work. If those adjustments aren’t made, a machine that may have been compliant when it was first set up can gradually become unsafe.

Inspections and employee awareness need to work together

Consistent inspections and effective training should work together. Inspections give employers a structured way to verify that abrasive wheel machines remain safe to use, especially after wheel replacement, maintenance activities, or extended periods of use. Training helps employees recognize the warning signs that may show up between those inspections, including unusual vibration, unfamiliar sounds, changes in performance, or equipment conditions that do not look right. Together, inspections and training should help employees evaluate:

• Wheel condition, including cracks, damage, or improper installation,
• Guard condition and proper placement,
• Excessive vibration, unusual sounds, or changes in performance,
• Signs of wear, loose components, or unauthorized modifications, and
• Conditions that require the machine to be removed from service.

Multiple layers of protection provide the best defense

No single safeguard eliminates every abrasive wheel hazard. The strongest programs use multiple layers of protection because wheel condition, machine adjustment, employee behavior, and PPE all affect whether the equipment is safe to use. Those layers should include:

Maintain effective machine guarding: Damaged, altered, or missing guards should be repaired or replaced promptly.

Establish preventative maintenance practices: Regular maintenance helps keep guards, adjustment points, and machine components in safe working conditions.

Encourage employee involvement: Employees should be encouraged to speak up and stop using equipment when something does not look, sound, or feel right.

Use appropriate personal protective equipment: PPE provides an additional layer of protection and works best when combined with engineering and administrative controls, not used as a substitute for them.

Key to remember: Consistent inspections, proactive maintenance, and employee awareness help prevent abrasive wheel equipment from becoming a serious injury hazard.

What causes electrical accidents?

Electrical accidents are caused by one or more of the following:

• Unsafe equipment and/or installation.
• Unsafe workplaces caused by environmental factors.
• Unsafe work practices.

An accident such as high-voltage shocks can cause serious injury or even death.

How can it hurt me?

The effects of an electrical shock on the body can range from a tingle to immediate cardiac arrest.

Electrical currents travel in closed circuits through conducting material. Workers can receive a shock when a part of their body comes into contact with the following:

• Both wires of an electrical circuit.
• One wire of an energized circuit and the ground.
• Part of a machine that is ’hot’ because it is contacting an energized wire and the ground.

Severe shock can cause more damage than can be seen by the naked eye.

Safety 101

Workers must:

• Always make sure equipment is de-energized.
• Maintain electrical equipment.
• Regularly inspect tools, cords, grounds, and accessories. Have damaged equipment taken out of service immediately.
• Always use safety features like three-pronged plugs, double-insulated tools, and safety switches.
• Make sure that all machine guards are in place.
• Keep electrical cables and cords clean and free from kinks. Never carry equipment by the cord.
• Avoid touching water, damp surfaces, ungrounded metal, or any bare wires if you are not protected. Wear approved rubber gloves when working with live wires or ungrounded surfaces. Rubber-soled shoes or boots should be worn when working on damp or wet surfaces.
• Avoid wearing jewelry or metal objects when working with electricity.
• Keep the required safe distance from energized parts.

If workers are working where there are electrical hazards, employers must provide them with the appropriate PPE. Ensure that the equipment remains de-energized during service and maintenance activities by using lockout/tagout procedures.

Key to remember

Ensure that workers are familiar with the safety procedures for the job they are assigned to do. They should always use good judgment and common sense when working around electricity.

Determining effective anchorage

Without secure, stable anchorage, even the most up-to-date fall protection system is useless. Not all anchorages are created equal, especially when loads are applied, so finding the right anchorage can be a challenge.

To identify an appropriate anchorage:

• Ensure the anchor point is rated to withstand 5,000 pounds per attached worker.
• Select the appropriate anchor type for the structural material (wood, metal, cement, etc.) on which it will be used.
• Verify fall protection systems are compatible with anchorages and have been identified by a qualified person to meet regulatory requirements. A qualified person is a person who, by possession of a recognized degree, certificate, or professional standing, or has extensive knowledge, training, and experience, has successfully demonstrated the ability to resolve problems relating to the matter at hand.
• Perform regular inspections of anchor points to ensure proper installation and maintenance.

When in doubt, anchor points should always be inspected and certified by an engineer before being used for fall protection.

What are some common anchorages?

Common fall protection anchor points for the attachment for lifelines, lanyards, or deceleration devices include:

• Permanent anchor points installed on buildings or structures,
• Parapet clamps,
• Portable dead-weight fall anchor points,
• Clamp anchors, or
• Non-penetrating anchor points.

Take advantage of May’s National Safety Stand-Down!

Coordinated by OSHA, NIOSH, and the Center for Construction Research and Training (CPWR), the 10th annual National Safety Stand-Down aims to raise awareness that fatal falls, like the one mentioned above, are preventable.

The voluntary event is held May 1-5, making May an ideal month for employers to educate or refresh employees about fall prevention, fall protection, and proper anchor points. Use near misses, fatal incident reports, and harness manufacturer manuals as training guides. And don’t be afraid to take workers on a field trip to identify approved anchor points in your workplace.

This would also be a good time to review your fall protection programs, including those that cover the use of personal fall arrest systems, to ensure they’re up to date.

Keys to Remember

Personal fall protection for workers is only as good as the anchorage point to which it’s fastened. Employers must ensure anchor points are approved, appropriate for the work being performed, and that workers can effectively identify and use these lifesaving devices.

Fixed guards

A fixed guard is just that — permanently fixed to the machine. It prevents workers from accessing dangerous moving parts of a machine. It’s a physical barrier that doesn’t rely on moving parts to function. Removing the barrier requires tools, so these guards are typically used on parts of machinery that aren’t accessed frequently, like a protective cover that fully encloses a machine’s flywheel.

OSHA requires that the barrier be made from materials that can withstand any impact it may receive and endure prolonged use, such as sheet metal, screens, and bars. Fixed guards are best suited for machines involved in high production with repetitive operations.

Interlocked guards

Opening or removing an interlocked guard on a machine shuts off or disengages the power and stops the machine’s moving parts. The machine can’t start again until the guard is back in place. Interlocked guards require electrical, mechanical, hydraulic, or pneumatic power (or a combination of these) to function. This is where the “interlocked” part comes in; these guards are interconnected with the machines they protect. For example, the bowl of an industrial food mixer with an interlocking guard can operate only when the guard is in position over the bowl, which prevents workers from coming into contact with the moving mixing device. When the guard is lifted, the power automatically shuts off, and the mixing device stops.

OSHA recommends making all removable guards interlocked to prevent occupational hazards. The guards must stop machines before workers can reach danger areas. Further, machines shouldn’t automatically restart when interlocked guards are put back in place. Interlocked guards are most effective on machines where operators need to regularly access the guarded parts for things like clearing jams or adding materials.

Adjustable guards

An adjustable guard is a movable barrier permanently fixed to the machine that can be adjusted for various production operations. A machine operator manually positions this type of guard and locks it into place. Due to the guard’s increased risk of injury, employers must establish proper administrative controls and train workers how to use adjustable guards.

Metalworking and woodworking machinery typically have adjustable guards, such as the guard on a horizontal milling machine that allows workers to change the size of the cutter. Adjustable guards are ideal for machines that process different sizes of materials and conduct various processes.

Self-adjusting guards

A self-adjusting guard places a barrier between the danger area and the operator that automatically adjusts to accommodate stock. When stock is moved into a danger area, it pushes the self-adjusting guard away, providing an opening into the machine that’s only large enough to allow the stock through. Once the stock is removed, the self-adjusting guard automatically returns to the rest position (either by gravity or a spring-loaded mechanism).

By automating the adjustment process, these guards eliminate some of the risks associated with adjusting guards. Self-adjusting guards are commonly used on woodworking machines like table saws.

Which guards should your facility use?

The ultimate purpose of all machine guarding is to eliminate or, if that’s not possible, control the hazards of operating or accidentally coming into contact with a machine. However, there’s not a one-size-fits-all solution to machine guarding. Employers must consider many variables specific to their industry, facility, operator involvement, and the machines they use and comply with any applicable regulations.

Machine-specific guarding requirements under 1910 Subpart O apply to:

• Woodworking machinery,
• Abrasive wheel machinery,
• Mills and calendars in the rubber and plastics industries,
• Mechanical power presses, and
• Forging machines.

In addition to the general industry standards at 1910.212, OSHA has industry-specific standards for:

• Maritime (1917 Subpart G and 1918 Subpart I)
• Construction (1926 Subpart I), and
• Agriculture (1928 Subpart D).

Key to Remember: Machine guards protect workers from the hazards of moving machine parts. Employers must determine which of the four types of guards (or a combination of them) works best for each machine.