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OSHA and common sense is a definite oxymoron. The failure to require documentation is not an oversight. It is a common practice in the majority of the OSHA standards

In accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520), OSHA must request Office of Management and Budget (OMB) approval of the collection of any information required in any safety or health standard. Approval is only granted if it is specific and deemed to be necessary and relevant data.

The OSHA standard states: 1910.178(q)(7) - Industrial trucks shall be examined before being placed in service, and shall not be placed in service if the examination shows any condition adversely affecting the safety of the vehicle. Such examination shall be made at least daily. Where industrial trucks are used on a round-the-clock basis, they shall be examined after each shift. Defects when found shall be immediately reported and corrected.

The OSHA standard gives no specific information as to what the inspection consists of. Because the standard is vague, OMB cannot grant documentation approval.

OSHA can only enforce regulations as written and presented in the Final Rule of the rule-making process. Any changes (other than typographical errors) require a new rule-making process. This is a long, time consuming, and expensive process.

Employers do not need documentation for OSHA. They need documentation for potential lawsuits, especially third party wrongful death suits. The records that should be kept are those that document that a problem was found and the supporting documentation that shows that the problem was corrected.

A million copies of a daily inspection that are signed off by the operator but likely never really performed are meaningless.
  • Posted 7 Apr 2012 09:08
  • Modified 7 Apr 2012 15:17 by poster
  • By joseph_h
  • joined 19 Mar'06 - 253 messages
  • Michigan, United States

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