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This edition's appendices contain OSHA's Field Operations Manual (FOM), Chapter 3, Inspection Procedures. In March 2009, OSHA released a revised Field Operations Manual, formerly called the Field Inspection Reference Manual. Further revisions followed in November 2009. Revised Chapter 3, Inspection Procedures, will familiarize the reader with OSHA's enforcement policies and procedures when an on-site inspection occurs.
We have included FOM revised Chapter 4, Violations, Section III, General Duty Requirements. Several commentators have noted that the most significant change in the FOM involves its interpretation of OSHA's General Duty Clause, specifically how OSHA may demonstrate than an employer or the relevant industry “recognized” a hazard. Section III, General Duty Requirements, provides additional clarity about the expansive types of sources that can show employer awareness or recognition of workplace hazards.
Interpretation Letters. OSHA's recent letters of interpretation reprinted in this edition allow employers and employees to see how the agency addresses certain compliance questions raised by the public. Specific issues addressed in the letters include discussions on OSHA's lack of authority to ban use of hexavalent chromium; OSHA's position on complying with an updated national consensus standard; using the Globally Harmonized System (GHS) to comply with OSHA's Hazard Communication Standard; medical exams and chest roentgenograms (x-rays) under OSHA's asbestos standards; guarding of access openings to fixed ladders; work-relatedness for recordkeeping of an injury resulting from horseplay, and recordkeeping for work-relatedness of an accident occurring during an off-site event, among many others.
Revision of standards referenced in the Acetylene Standard. On August 11, 2009, OSHA has issued a direct final rule that revised its Acetylene Standard by updating references to standards published by standards developing organizations (SDOs). The direct final rule will became effective on November 9, 2009.
Updating OSHA Standards Based on National Consensus Standards; PPE. On September 9, 2009, OSHA issued a final rule revising the personal protective equipment (PPE) sections of its general industry standards concerning requirements for eye- and face-protective devices, and head and foot protection. OSHA updated the references in its regulations to reflect more recent editions of the applicable national consensus standards that incorporate advances in technology. The final rule became effective on October 9, 2009.
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