Is marijuana testing worth it? When to be the weed whacker

What’s changing and why it matters

Although EPA has been deregulating or loosening some requirements, there are still some standards being tightened across multiple fronts in the coming year:

• Renewable fuel standards (RFS): The EPA proposed higher volume requirements for 2026, including 24.02 billion renewable identification numbers (RINs), up nearly 8% from 2025. This increase pushes stricter expectations on fuel producers and organizations purchasing renewable fuels.
• Stormwater multi-sector general permit (MSGP): A new MSGP set to take effect by February 2026 will require quarterly PFAS indicator monitoring, expanded benchmark sampling, and resiliency measures in stormwater control designs.
• PFAS Reporting under the Toxic Substances Control Act (TSCA): TSCA Section 8(a)(7) mandates PFAS manufacturing and import data collection beginning in April 2026, through October 2026, with extended deadlines for certain small manufacturers.

Failure to prepare could lead to fines, reputational damage, supply chain disruptions, and permit delays. Companies that weave compliance planning into their 2026 strategy will be positioned not just to meet legal deadlines but to sustain operations smoothly.

Key areas of impact

• Renewable fuel standards (RFS) and air emissions The proposed increase in 2026 Renewable Identification Numbers (RIN) volumes, from 24.02 billion to 24.46 billion for 2027, signals tightening air and fuels policy that affects fuel use and emissions accounting.
• Stormwater management The upcoming 2026 MSGP requires expanded quarterly PFAS monitoring, new benchmark triggers, corrective action plans, and integration of climate resilience in design standards.
• PFAS disclosure (TSCA Section 8(a)(7)) Manufacturers and importers of PFAS must submit electronic reporting of usage, volumes, disposal, and exposure data between April and October 2026, with extensions available for smaller operations.

Steps to take now

• Audit compliance programs: Cross-check operations against RIN inventory, stormwater permits, and TSCA reporting duties.
• Upgrade monitoring and recordkeeping: Implement robust electronic systems to track PFAS, stormwater quality, fuel volumes, and emissions.
• Staff training: Educate teams on PFAS obligations, new stormwater protocols, and RFS structures.
• Engage regulators early: Comment on proposed rules, consult during permit drafting, and flag issues during the notice-and-comment period.

Looking ahead

The EPA’s 2026 updates reflect a trend toward increased transparency and environmental accountability. Companies that treat compliance as strategic will not only avoid enforcement but also gain resilience and stakeholder trust.

Key to remember: Start planning now. Early action on EPA rule changes will save time, money, and headaches when enforcement begins.

What is used oil?

The EPA defines used oil as any petroleum-based or synthetic oil that has been used and is contaminated by physical or chemical impurities. Common sources of used oil in industrial operations include:

• Motor oil and lubricants from vehicle maintenance
• Hydraulic fluids used in heavy machinery
• Metalworking fluids and coolants
• Compressor oils used in air compression systems

According to EPA regulations (40 CFR Part 279), used oil is presumed to be managed under the less stringent used oil management standards unless it meets hazardous waste criteria.

Used oil becomes hazardous waste if:

• It is mixed with hazardous waste (e.g., solvents or heavy metals)
• It contains more than 1,000 parts per million (ppm) of total halogens, unless proven otherwise, or
• It is disposed of improperly, leading to environmental contamination.

If used oil is classified as hazardous waste, it must be managed in accordance with the applicable solid and hazardous waste requirements.

EPA requirements for used oil disposal

The EPA requirements for used oil consist of three different aspects, as outlined below.

1. Storage Requirements

Use leak-proof tanks and containers made of durable, non-earthen materials (e.g., steel, plastic, or concrete). Label all used oil containers with the words "Used Oil" to prevent misidentification. Prevent leaks and spills by using secondary containment systems and regularly inspecting tanks. Never mix used oil with hazardous waste unless authorized.

2. Transportation and Disposal

Used oil generators may transport up to 55 gallons of used oil to a registered collection center without an EPA ID number. If contracting a used oil transporter, ensure they have an EPA Identification Number.

Used oil must be:

• Recycled or re-refined into new oil.
• Burned for energy recovery in approved furnaces or boilers.
• Disposed of at an authorized hazardous waste facility if deemed hazardous.

3. Spill Prevention and Cleanup

Facilities storing large amounts of used oil must have a Spill Prevention, Control, and Countermeasure (SPCC) Plan. SPCC plans establish procedures, methods, and equipment requirements to prevent oil from reaching waterways, and to contain discharges of oil.

Any spills must be cleaned up immediately, and absorbent materials must be disposed of properly. Rags and shop towels contaminated with hazardous materials may be classified as hazardous waste.

OSHA regulations for handling used oil

While the EPA focuses on environmental compliance, OSHA (29 CFR Part 1910) regulates worker safety when handling used oil. Key OSHA requirements include:

1. Personal Protective Equipment (PPE)

Workers handling used oil must wear gloves and protective clothing to prevent skin exposure. Safety goggles or face shields are also important to avoid eye contact.

2. Hazard communication (HazCom) program

Employers must label all used oil containers with appropriate hazard information and train employees on safe handling procedures and emergency response.

3. Fire and Explosion Safety

Always store used oil away from ignition sources to prevent fire hazards. Ensure storage areas are ventilated to avoid vapor buildup.

State-Specific used oil disposal regulations

Many states have stricter used oil regulations than federal laws. For example:

• California classifies used oil as hazardous waste unless it meets specific recycling criteria.
• Texas requires additional storage permits for large generators.
• New York mandates annual reporting on used oil disposal activities.

To ensure compliance, check with your state’s environmental agency for state-specific used oil disposal rules and whether used oil is considered hazardous. Additional permits for transporting or processing used oil may be necessary.

Staying compliant with used oil disposal requirements

Ensuring compliance with EPA, OSHA, and state laws is essential for safety managers and shop supervisors handling used oil. By following proper storage, transportation, and disposal practices, businesses can reduce environmental risks, improve workplace safety, and avoid costly fines.

Key to remember: By staying informed and proactive, your facility can maintain safe, sustainable, and compliant used oil management practices.

Impact on the workplace

The order doesn’t address how the rescheduling of medical marijuana impacts compliance with other federal laws, but to avoid the risk of a discrimination claim under the federal Americans with Disabilities Act, employers in states where medical marijuana is legal should treat individuals using medical marijuana as they would treat any individual using a prescription medication.

This includes having a discussion with the employee about accommodations, which may include off-duty use of medical marijuana.

In states where medical marijuana isn’t legal, employers would only need to consider accommodations for use of marijuana products approved by the FDA.

Recreational marijuana considerations

The order doesn’t legalize recreational marijuana, but does announce a June 29 hearing to evaluate broader changes to marijuana’s status under federal law.

The order notes that it doesn’t apply to synthetically derived THC, such as Delta-10 products. The final order notes that synthetically derived THC is outside of the definition of marijuana.

The order also establishes a federal licensing system for state medical marijuana manufacturers and dispensaries. It notes that states where medical marijuana is legal have established systems to regulate the sale and use of medical marijuana.

How does this affect safety-sensitive jobs?

The Drug Enforcement Administration’s reclassification order doesn’t address the impact the change would have on federal drug testing regulations. Specifically, it doesn’t offer insights into Department of Transportation (DOT) drug testing of truck drivers, airline pilots, pipeline operators, and others in safety-sensitive positions.

Before any changes can be implemented by the DOT, drug testing procedures in 49 CFR Part 40 must go through the rulemaking process.

Key to remember: The federal government has moved medical marijuana to a lower classification of drug. To reduce the risk of a discrimination claim, employers in states where medical marijuana is legal should treat it as a prescription medication to lower the risk of a discrimination claim. Employers in all states should consider accommodations for FDA-approved marijuana products.

To-do before October 1

Get ready for renewal by taking the following steps now:

• File all your highway use tax returns that are due.
• Pay your taxes. The state will not issue a new certificate of registration if you owe back taxes. Before you apply to renew, make sure that you’ve paid all taxes due under any of the programs administered by the New York State Tax Department, including:
  • HUT,
  • personal income tax,
  • International Fuel Tax Agreement (IFTA),
  • sales tax, and
  • withholding tax.
• Create an online account if you do not already have one and you want to renew your credentials and pay online (https://www.oscar.ny.gov/).
• Make sure your vehicle registration information is correct and accurate. Review and update your information as soon as possible. Incorrect information will delay the processing of your certificates and decals.

Beginning October 1

Once the renewal period opens, renew your credentials and pay your renewal fees online with One Stop Credentialing and Registration (OSCAR).

Submit your renewal application by November 30, 2024, to make sure you receive your decals in time to place them on your vehicles before January 1, 2025.

If you are already enrolled in OSCAR, use your current OSCAR password to renew online.

If you are not enrolled, visit OSCAR, and select Enroll Now. You must have a United States Department of Transportation (USDOT) number and an employer identification number (EIN).

To renew your registration:

1. Visit the OSCAR website and select HUT Renewal from the Business Type drop-down.
2. Enter your information in the USDOT#, NYS Tax ID#, and Password fields, then select Log in.
3. If you have 300 or fewer vehicles, choose either:
   1. Renew all HUT/AFC Certificates of Registration to renew all your active current series permits, or
   2. Select HUT/AFC Certificates of Registration to renew specific permits.
4. If you have more than 300 vehicles, choose either:
   1. Renew all to renew all your active current series permits, or
   2. File renewal to renew select permits.

If you are unable to renew electronically, you may file Form TMT-1.2, Renewal Application for Highway Use Tax (HUT) and Automotive Fuel Carrier (AFC) Certificates of Registrations and Decals – 25th Series.

Key to remember: Take steps now to renew your NY HUT and ensure you receive your new decals before the current ones expire.

Differences between states

Since other states may not accept a home state’s gun license — and there is not national reciprocity — drivers who wish to take along a personal firearm must check whether the states in which they travel:

• Have a concealed-carry law,
• Accept another state’s concealed-carry permit, and
• Have any concealed-carry differences from their home state’s allowances.

Also note that possession of other weapons (e.g., knife, bat, club) might be a state or municipal criminal offense. Mace may also be considered a weapon based on jurisdiction and is restricted to some extent in all states.

Crossing into Canada with a gun

Crossing the Canadian border with a gun is much different than traveling through different states.

First, the U. S. Department of State requires travelers to file Electronic Export Information for temporary export of personally owned firearms. Travelers must use the Automated Export System prior to departing the United States so the gun can re-enter the United States. Individuals must complete CBP Form 4457, a form used when U.S. travelers take personal effects abroad. If taking ammunition, and there is a possibility it will not be used while outside the United States, it must be re-imported along with the gun using CBP Form 4457.

Next, travelers must declare firearms to the Canada Border Services Agency (CBSA). Visitors must have necessary documents available for border agents, and the weapon must be stored and transported properly. In addition, visitors need to be aware that Canadian law prohibits more than 1,500 models of assault-style firearms.

If a driver arrives at the Canadian border with an undeclared firearm, the following consequences can occur:

• Significant delay at the border
• Fines
• Criminal charges
• Confiscation of the undeclared gun
• A ban on the driver from returning to Canada

Anyone wishing to enter Canada with a firearm should compete the Non-Resident Firearms Declaration form before arriving at the border. The form should not be signed prior to reaching Canada because a CBSA customs officer must witness the gun owner’s signature. The Declaration is considered a temporary license that is valid for 60 days. A fee of $25 is charged to the traveler for this temporary permit. The Declaration can be renewed for free before it expires.

Re-entering the United States with a gun

There is a similar process when re-entering the United States with a previously exported firearm. Upon returning to the United States, a traveler must make a regular declaration regarding the personal effects and goods that they are carrying and ensure that they declare any firearm and ammunition.

The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) regulations allow for the use of the CBP Form 4457 upon re-importation, and does not require an approved import permit, provided that CBP is satisfied that the firearm was previously exported from the United States and is now being returned.

Create a company policy on weapons

The hot topic of gun ownership and concealed-carry laws may be an opportunity for motor carriers to weigh the pros and cons of allowing their commercial drivers to carry a weapon where permissible.

Carriers may need to speak with their insurance provider and/or an attorney as it comes to a decision.

In addition to weapons in CMVs, a policy needs to address:

• Concealed-carry permits at motor carrier facilities, and
• Abiding by a weapons policy at customer locations.

Whichever direction the motor carrier takes, drivers need to know the policy so there is little doubt about the company’s stand on the matter.

Do exempt carriers need to have proof of insurance?

Carriers that haul exempt commodities are required to have the minimum level of financial responsibility required by 49 CFR 387, and their insurance provider must provide the carrier with an MCS-90 endorsement. However, the insurance need not be on file with the FMCSA. Many states have insurance requirements both for the amount required and the need to carry proof of coverage in the vehicle. Federally exempt for-hire carriers are not exempted from any state requirement.

Are exempt for-hire carriers required to name process agents?

Currently, exempt-for hire carriers are not required to name process agents for each state of operation as other for-hire carriers are required to do so on the BOC-3 form. That may change when the FMCSA fully implements their Unified Registration System, or URS. The system was introduced with a final rule in the summer of 2013 and included a provision requiring exempt carriers to have process agents. Much of the rule was suspended at the beginning of 2017. At some point, the agency would like to get the URS ball rolling again.

Are exempt carriers exempt from IFTA, IRP, HVUT, and UCR?

Exempt for-hire carriers are not exempt from the alphabet soup of revenue generating programs of the International Fuel Tax Agreement (IFTA) allowing for the sharing of fuel tax revenue, the International Registration Plan (IRP) allowing for the sharing of vehicle registration fees, the Internal Revenue Service’s (IRS) tax for heavy vehicles that weight 55,000 pounds or more, or for the Unified Carrier Registration (UCR) revenue generating program.

Are exempt carriers exempt from the Federal Motor Carrier Safety Regulations (FMCSRs)?

Exempt carriers are not automatically exempt from the safety regulations such as driver qualifications, drug and alcohol testing, commercial driver licenses, vehicle inspections, or the hours-of-service rules. Although livestock and agriculture commodity carriers may qualify for the hours-of-service agriculture exemption.

Key to remember: “Exempt” commodity haulers are exempt from very little. Primarily they are exempt from needing for-hire authority and designating process agents.

Health care settings

Health workers worldwide face a high risk of violence, with 8–38 percent experiencing physical attacks, while others are subjected to threats or verbal abuse, according to the World Health Organization (WHO). Most incidents involve patients or visitors. Those at greatest risk include nurses, patient-facing staff, emergency room personnel, and paramedics.

Violence against health workers harms staff well-being, morale, and retention, ultimately compromising quality of care and causing significant financial loss.

An OSHA proposed rule — ‘Workplace Violence in Health Care and Social Assistance’ — was moved to Long-Term Action status, according to the Spring 2025 regulatory agenda that was released on September 4, 2025. Long-Term Actions are items under development, but the agency doesn’t expect to have a regulatory action within the 12 months after the latest edition of the agenda.

This turn of events was surprising since OSHA had been working on a standard for preventing workplace violence in health care and social assistance settings. OSHA had planned to publish the proposed rule in the Federal Register in June 2025.

Even without a federal standard addressing workplace violence in health care, several states have their own health care violence prevention laws in place.

General Duty Clause

Although OSHA doesn’t have a workplace violence standard, employers must provide a workplace that’s free of known health and safety hazards. This is addressed in OSHA’s General Duty Clause (GDC), Section 5(a) of the Occupational Safety and Health (OSH) Act.

The following elements are necessary for OSHA to prove a violation of the GDC:

• The employer failed to keep the workplace free of a hazard to which employees of that employer were exposed;
• The hazard was recognized;
• The hazard was causing or was likely to cause death or serious physical harm; and
• There was a feasible and useful method to correct the hazard.

A general duty citation must involve both the presence of a serious hazard and exposure of the cited employer’s own employees.

During a violent incident investigation, OSHA inspectors would likely gather evidence about whether an employer knew that a potential workplace violence hazard existed and whether there were feasible means to prevent or minimize such hazards. Investigators might also look at evidence of any potential whistleblower retaliation in which workers complained about workplace violence risks or reported injuries from workplace violence incidents.

Health care facilities have been cited when staff were injured by violent patients or visitors. In one case, nurses were regularly assaulted, but the hospital had no prevention program, no staff training, and no reporting system. OSHA stepped in using the GDC. Prevention could have included de-escalation training, secure facility layouts, panic buttons, and post-incident support.

Tips for preventing violent acts

In most workplaces where risk factors can be identified, violent acts can be prevented or minimized.

Building respectful workplaces is one way to do this. The most common forms of uncivil behaviors are when employees:

• Address others in disrespectful ways,
• Interrupt those who are speaking, and
• Micromanage people to an excessive degree.

Providing employees with civility training — which differs from anti-harassment training — can help to create more respectful work environments with less conflict. While civility training isn’t only focused on preventing harassment, that could be a component.

Research has shown that incivility can be a precursor to harassment. In contrast to anti-harassment training, civility training tends to give employees positive examples of how to behave, versus actions to avoid.

The training typically includes a focus on:

• Interpersonal communication,
• Conflict resolution, and
• Effective supervisory techniques.

How civility training is presented will depend on the size of the workforce, demographics, location, industry, etc. There is no one-size-fits-all approach. The point is to get employees to be more aware of how their words and actions impact others, and how they should treat everyone with respect.

It’s also important to watch for signs that someone could turn violent. While there’s no guarantee that one or more questionable behaviors equate to a potential incident, some warning signs come from someone experiencing personal or work issues.

They could be struggling financially, going through a divorce, or having health issues. Work triggers could stem from negative employment actions, like a demotion or termination, or other types of conflict.

Key to remember: April is Workplace Violence Prevention Month. Now’s the time to focus on ways to keep all employees safe.

FMLA certification basics

Employers aren’t required to use certifications, but if they do, the U.S. Department of Labor (DOL) has five different certification forms to use for various FMLA leave situations.

The forms are as follows:

1. Certification of Health Care Provider for Employee's Serious Health Condition,
2. Certification of Health Care Provider for Family Member's Serious Health Condition,
3. Certification of Qualifying Exigency for Military Family Leave,
4. Certification for Serious Injury or Illness of a Current Servicemember for Military Family Leave, and
5. Certification for Serious Injury or Illness of a Veteran for Military Family Leave.

Let’s focus on the first two, as these are the most common ones HR administrators use.

Who can fill out an FMLA certification?

The FMLA regulations describe the person who has the authority to fill out a certification as a “health care provider.” The good news is, the regulations include a lengthy list of medical professionals who fit this role.

Under the FMLA, a health care provider includes:

• A doctor of medicine or osteopathy,
• A podiatrist,
• A dentist,
• A clinical psychologist,
• An optometrist,
• A chiropractor (limited to manual manipulation of the spine as demonstrated by X-ray),
• A nurse practitioner,
• A nurse midwife,
• A clinical social worker,
• A physician assistant,
• A Christian Science practitioner, and
• Any health care provider from whom the employer or the employer's group health plan's benefits manager will accept a medical certification to substantiate a claim for benefits.

To be qualified to fill out FMLA forms, medical professionals must be authorized to practice in the state and perform within the scope of their practice. This means that the provider must be authorized to diagnose and treat physical or mental health conditions.

What about doctors in a foreign country?

If an employee or an employee's family member is visiting another country, or a family member resides in another country, and a serious health condition develops, the employer must accept a medical certification from a health care provider who practices in that country. This includes second and third opinions.

If a medical certification from a foreign health care provider is not in English, the employee may be required to provide a written translation of the certification.

Key to remember: The FMLA regulations spell out which medical professionals can fill out certification forms.

Who HIPAA covers

The HIPAA privacy provisions apply to employers only in their activities as group health care plan sponsors. If an employee, for example, asked an HR representative whether the company’s group health plan covered her particular health condition, HIPAA would apply, and the HR representative would need to keep that information private.

HIPAA’s privacy rules don’t apply to employers in other activities. Therefore, asking for FMLA certifications from employees doesn’t involve the HIPAA rules.

Other entities covered by HIPAA rules include health care providers, such as doctors, nurses, and medical staff. They may not disclose PHI with some exceptions, such as if an employee signs an authorization to release the PHI.

Taking the doctor out of the conversation

Employers have the right to ask employees for FMLA certifications. They give employees a certification form and ask that they have the doctor complete the relevant parts. Often, the doctor then gives the completed form back to the employee who, in turn, gives it to the employer. The doctor doesn’t give the certification directly to the employer.

When doctors give completed FMLA certifications to patients/employees, no HIPAA violation exists because it’s the patient’s information. The patient (or family member), then has the right to disclose their PHI to whomever they want, including the employer.

Putting the doctor into the conversation

Employees may ask that a doctor send a completed FMLA certification directly to the employer. In that situation, the doctor will require the employee/patient to sign a HIPAA disclosure authorization. That’s where the HIPAA privacy comes into play.

Employers may not force employees to ask that doctors send the certification directly to them. Employees have the right to get the certification from the doctor and then give it to the employer.

Once requested, employees are responsible for getting the certification to the employer. If employees don’t, whether they get it from a doctor or have the doctor send it to the employer, they risk their FMLA protections.

When employers may directly contact the doctor

Under the FMLA, employers may contact an employee’s health care provider only after receiving a complete and sufficient certification, and only for authentication or clarification of the certification. Only a health care provider, an HR professional, a leave administrator, or a management official may make such contact. In no case may the employee’s direct supervisor contact the employee’s health care provider. Employers may not, however, ask the health care provider for additional information beyond that contained on the medical certification form. Therefore, this request does not trigger HIPAA privacy rules.

Key to remember: Employers don’t violate HIPAA if employees get a certification from a doctor and then give it to the employer. Otherwise, doctors must get a HIPAA disclosure authorization from the patient to directly give a certification to the employer.

Shared versus individual handbooks

Nearly 60 percent of survey respondents bought one handbook (or a few) and shared them among employees, while 42 percent provided individual handbooks for each employee. Of those who purchased one or a few, they typically kept the handbooks in central or safety-related locations, such as:

• Main offices
• Safety or compliance offices
• EHS departments
• Classroom or training spaces
• Shared libraries near Safety Data Sheet binders or training areas
• Shop floors near work areas

Use in training programs

As mentioned, the majority of those surveyed said they use safety handbooks as part of new hire, ongoing, and refresher training. This includes the following uses:

• Building or supporting existing training programs
• Creating quizzes or review questions
• Supporting skills testing (e.g., forklift, ladder, PPE)
• Providing supplementary materials for:
  • Toolbox talks
  • OSHA 30 courses
  • Job-specific trainings (e.g., load securement, bloodborne pathogens, Federal Motor Carrier Safety Regulations)

Additional survey feedback

Open-ended survey responses highlighted that some companies prefer visual presentations or digital formats over print publications, with some expressing concern that hard copy materials may quickly become outdated. Others said they use handbooks only as background reference for the EHS team and see a need to increase handbook use in their company.

Key to remember: Safety handbooks can serve as a core part of safety and health programs by giving employees and supervisors a shared reference for training conversations and expectations.

Ladders feel safe, until they’re not

Ladders don’t usually trigger a sense of risk because they’re seen as a part of everyday work. When tasks feel quick and familiar, people don’t always stop reassessing the setup. That’s how unsafe ladder habits with big consequences can develop, including:

• standing on the top step “just for a second;”
• reaching too far instead of climbing down;
• using whatever ladder is closest, not the right one; and
• skipping ladder inspections because “it worked last time.”

Ladder safety isn’t going away, and that’s not a bad thing

If ladder safety feels like a repeat conversation, that’s because the same risks keep showing up. New employees are hired; facilities and equipment changes, and old habits stick around longer than they should. Even experienced workers fall into this trap. Familiar tasks start to invite rushing. Rushing leads to shortcuts, and shortcuts are where ladder injuries happen.

Emphasis must be placed on recognizing the risk before the climb starts. This means knowing when a ladder is the wrong choice, repositioning is safer than reaching, and when a quick task deserves the same setup as a longer one.

Most incidents don’t start with bad intentions. They start with “just this once” decisions, one more rung, one quick reach, one skipped check. Effective ladder safety training is about breaking routines and refocusing attention on the decisions that make ladder work safer.

Routine work, repeat injuries

Ladder injuries follow a familiar pattern. They don’t usually come from unusual jobs or unexpected hazards, and they happen during everyday tasks that feel common. Injury reports often look the same, such as short tasks, quick setups, and decisions made under time pressure. The ladder didn’t fail. The setup and the decisions around it did.

Injury data from OSHA and the Bureau of Labor Statistics (BLS) consistently point to the same causes. That’s why the same types of ladder injuries keep occurring repeatedly, not because the hazards are unknown, but because routine work makes those hazards easier to overlook. These reasons include:

• people underestimate the risk because ladders feel familiar;
• jobs feel “too small” to stop and reset the ladder;
• time pressure encourages leaning, rushing, and overreaching; and
• experience leads to comfort, and comfort leads to shortcuts.

The rules are written in injuries

OSHA ladder requirements are built around real injury trends and are based on decades of injury data. Falls from ladders remain one of the leading causes of workplace injuries, which is why OSHA keeps ladders near the top of its enforcement priorities year after year:

OSHA 29 CFR 1910.23 defines how ladders are intended to be used, specifically prohibiting practices such as standing on the top step of a stepladder, using ladders for purposes they were not designed for, and climbing ladders that have not been inspected. These requirements exist because improper use, poor setup, and skipped inspections consistently show up in ladder fall investigations.

OSHA 29 CFR 1910.30 reinforces that preventing ladder injuries depends on training employees to recognize hazards before they climb, understand proper ladder selection and positioning, and know when a ladder is not the right tool for the task. Together, these standards emphasize that ladder injuries are not random events, they are predictable outcomes of routine decisions made during everyday work.

Small choices make a big difference

Ladder safety isn’t only about compliance. Incidents develop from a series of small, moment to moment decisions made during routine work. These choices made daily either reduce risk or quietly add to it. Ladder injuries can be avoided by taking the time to make simple improvements including:

• inspecting and securing the ladder,
• climbing down and repositioning,
• selecting the proper ladder for the task, and
• stopping when the ladder no longer feels stable or safe.

Key to remember: Take the time to choose safer setups, stay alert, and prevent routine decisions from turning into preventable injuries. When employees choose the correct ladder, reposition instead of reaching, and inspect before use, the risk of ladder injuries falls, not your employees.

Understand impairment concerns

Employers may have concerns for those workers with a hearing and/or vision impairment that wish to be trained as forklift operators. By recognizing potential safety issues, they can work to implement appropriate measures for the operator.

Around 15 percent of adult Americans say they have trouble hearing. For those with a hearing impairment, potential safety concerns with forklift operation may include difficulty or inability to hear the following:

• pedestrians nearby;
• horns or other warning signals;
• verbal instructions and training;
• other equipment;
• potential malfunction of the forklift; and
• emergency signals.

In addition, 18.4 percent of adult Americans are either blind or experience “a lot” or “some” visual impairment, even with corrective glasses in place . Potential safety risks associated with forklift operation for those who have a vision impairment may include:

• inadequate depth perception;
• insufficient peripheral vision;
• difficulty seeing pedestrians; and
• trouble differentiating different work environments.

Focus on appropriate measures

Hearing and vision impairment does not mean forklift operation is impossible, it simply suggests the employer may need to consider reasonable accommodations and implement appropriate measures for the operator.

For those with hearing impairments, this could include:

• installing vibrating alarms or lights to notify the operator of potential threats;
• utilizing hand signals or written instructions as a form of communication;
• increasing usage of mirrors and/or cameras to improve situational awareness; and
• providing specialized training for operators with hearing impairments.

For those with vision impairments, this could include:

• installing audible proximity detectors or sensors;
• enforcing pedestrian walkways and requiring hi-vis apparel;
• establishing clear communication methods and large signage where appropriate;
• maintaining floor markings, clear pathways, and adequate lighting; and
• providing specialized training for operators with vision impairments.

Remember the operation requirements

At a minimum, workers must receive proper training and certification before being allowed to operate a forklift. Such training includes a combination of formal instruction, practical training, and evaluation. Operators must be re-evaluated every three years, and refresher training provided to those who meet certain criteria. Also keep in mind, it is a violation of Federal law for anyone under the age of 18 to operate a forklift regardless of ability.

Key to remember

Ultimately, it is up to each employer (with a physician’s guidance, if necessary) to determine if an employee can operate the forklift in a safe manner.

Electronic storage doesn’t mean an internet search

Employers may make SDSs available to employees on a company website or contract with an off-site/web-based SDS provider. It’s not acceptable to require employees to perform an internet search to view or obtain an SDS.

If you maintain SDSs electronically, you must ensure that:

• All employees have adequate computer access, with no restrictions;
• There’s a backup procedure or system (e.g., paper, another electronic system) in place in case the primary system isn’t functioning;
• Employees are trained on how to access the SDSs (both on the computer and the backup procedure or system); and
• There’s a procedure or system in place to ensure that employees can receive a hard copy if they request one and in cases of emergency (which must be transmitted to medical personnel). It’s not acceptable to only transmit the information verbally.

Back it up!

What does OSHA mean by a backup procedure or system? This could be as simple as hard copies of SDSs in binders. If the internet or power goes down, it’s the most reliable option. However, if you have hundreds (or thousands!) of hazardous chemicals, this can be a challenge to maintain. I asked two of my colleagues about their industry experience with SDSs. One colleague said that in his previous position, he printed his SDS library once a year and kept the file in his office, but also placed the SDS inventory on a backup drive that he could access on another computer if necessary.

Another colleague said a second server may be an option, or an up-to-date thumb drive that can be plugged into another computer (provided there’s power). A lot depends on if power outages or internet interferences are of concern (which can be the case at any time). Some employers have the luxury of a secondary location that could provide digital access for some employees, but usually paper backups are the fallback.

Key to remember: If you store SDSs electronically, make sure you meet OSHA’s requirements, including that of a backup system or procedure.