Discuss how, as a safety professional, you would respond to the overlap in Occupational Safety and Health Administration (OSHA) standards and state or local building, electrical, and life safety codes. What would be the most significant challenges?
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Over the years I have seen some pretty significant challenges when a company has to deal with several compliance organizations that ask for slightly different things when dealing with the same type of hazard or situation. A good example would be a recent client that is an excavating contractor that does a lot of work for the railroad. When they are not on railroad property, they fall into the OSHA standards. When they are in the gravel pit, they fall into MSHA’s region. On the road, they follow DOT guidelines and when working on the railroad, it is under the FRA. Now, factor in the fact that we are in a state with a state-run plan and it can become extremely confusing for all the workers. So, I think the biggest challenge would be in educating the employees. They weren’t hired because they knew the rules. They are hired because they have certain skills needed and now, they are being asked to know the differences in the regulations. This group also has the potential to cross state lines, which adds another element of confusion.
Another issue that I ran into one time, was a company had just finished a new addition on their existing building. They brought the Fire Marshal in to inspect it and to help set up their fire extinguishers. The Fire Marshal stated that since they had a fire suppression system installed, they did not need extinguishers according to the local fire code. Of course, this contradicts the OSHA standards and we corrected it immediately. This goes to show you that even supposed subject matter experts can get confused from time to time.