b'28 OSHA UPDATE (continued from pg 26)load of at least 5,000 pounds per employee orsoOSHAconcludedthattheemployerwasin is designed in compliance with the requirementsviolation of 1926.592(d)(15). The employer failed of1926.502(d)(15)(i)and(ii),theytieofftoto consider any possible alternative and never anything at hand. These alternatives state thatgottothequestionofwhetheritsanchorage the anchorage must be part of a complete fallpointwasincompliancewith1926.502(d)(15)arrestsystemwhichmaintainsasafetyfactor(i)and(ii).IraisethisissuebecauseIfind of at least 2 and which is under the supervisionthatfrequently,employeesinthefieldwilluse of a qualified person. I raise this issue becauseexpedient measures to accomplish a task without recently I have become aware of citations beingfollowing the rules. In a situation such as the one issued for violations of 1926.502(d)(15) becauseI have outlined, employees are likely to tie off to theemployerwasnotusingandcouldnotanything that appears to be solid without ever demonstrate that their anchorage point met thetaking any steps to confirm their belief. I believe 5,000 pounds per employee requirement.the subparts I have discussed above can give the employer an alternative to installing a 5,000 In one case, the employer had its employeespound per employee rated anchorage point, but loop their safety line through the sheet metal basethey will only come into play if a qualified person of an HVAC unit using an aluminum carabiner that(under the definition in 1926(32)(m) has made a hadnoweightrating.Tomakemattersworse,determination of the safety factor of the proposed the set-up had not been approved or installedanchor point. I must recommend complying with by a qualified person. No effort had been madetherequirementforananchoragepointwitha to determine the load bearing limits of the sheet5,000poundloadfactorperemployee.Ifyou metal base or the load limits on the carabiner,choose to rely on the provisions of (i) and (ii), be sure you have involved a qualified person Dedicated to keeping its members at the forefront in their industryin establishing your anchor point. State Plan States I have discussed the requirements of state plan state programs in the past. But someofthedifferenceshavebecome moreapparentsinceCOVID-19.Ifyou are going to perform work in a state plan state,remembertherulesthatgovern Manufacturer of NDT Inspection Plugsthe work you are going to perform, even and NDT Inspection Point Labels thoughyouarebasedinastatewhere safetyisgovernedbyfederalOSHAor youarebasedinadifferentstateplan state. For example, Virginia has adopted averydetailedEmergencyTemporary Standardforemployeeexposuresto COVID-19. Other state plan states have eitheradoptedemergencyguidanceor are in the process of adopting emergency temporarystandards.Beawarethat guidanceinastateplanstate,ifmore ISO 9001:2015 Certified Qualitystrictthantheguidancereliedonby Management System federalOSHAtoprotectemployeesin The InsulatorJanuary 2021'