Monthly Archives: August 2016

Managing Used Oil

If you use, handle or store used oil, then you may have regulatory relief provided that the oil is recycled or re-purposed. In this example, we will briefly discuss used oil heaters. Some jurisdictions allow the use of used oil heaters to heat buildings – for example a metal barn. In any case, remember to label the containers (such as drums) of used oil correctly – stating for example: “Contents: Used Oil.” Check with your local jurisdiction to be sure of their requirements. Also store the used oil in compatible, closed containers preferably within secondary containment to reduce the likelihood of environmental harm should there be a leak or spill.

Hot Work and Fire Safety

Remember to implement formalized methods to manage hot work at your business. Whether it is work conducted by your own employees or by contractors, use of open flame for tasks such as welding requires task planning and preparation of the work area. Besides fire safety considerations, if not properly managed, some welding and cutting operations can produce explosive hazards and other dangers as well.  Seek applicable information on hot work and implementing a hot work program from OSHA, or industry sources. As an added reference, please see:


Understanding Aspects of the 29 CFR 1926 Fall Protection Construction Standard

In brief, we have determined that some entities interpret the OSHA fall protection standard for construction differently than perhaps OSHA intends. As such, we will address one specific item in particular. Normally, when on an elevated work platform such as a roof, there must be compliant fall protection in place. This may include barriers or personal fall protection PPE, among other means of protection. However sometimes the relief granted in 29 CFR 1926.500 may be exploited beyond practical interpretation of the Standard. Take for example an inspector visiting a roof top to take measurements or perhaps only to photograph the roof.  If their visit to the roof can be reasonably coupled with construction activity (pending, current or recently completed), they are granted relief in that they need not wear fall protection PPE. Per position and interpretation letters from OSHA, this relief turns on the expectation from OSHA that the person or persons on the roof (or other elevated work platform) are not conducting tasks that require focused trade type work. But use caution when applying this relief.  While OSHA seems to not have attached a definitive time window on applying this relief, if there is no reasonable timeframe of attachment to pending, current or completed construction, by default, this relief is null. In other words, don’t send personnel onto a roof to for example take photos for an insurance property survey years after construction and expect that their activities are covered under 1926; in our view, they are not.

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