Front cover of current VOSH ARM
VOSH Administrative Rules Require Compliance with Manufacturers’ Guidelines -
This is BIG.
This is Virginia-specific information but really should be of interest to all safety and health professionals.
In the fall of 2005, the Virginia Safety and Health Codes Board considered the Virginia Department of Labor & Industry’s request to update 16VAC 25-60 better known as the VOSH Administrative Regulations Manual. Anna Jolly, JD, CHMM, my business partner here at Circle Safety, is a long-time member of the Codes Board. She received a briefing package of the proposed language and attended the March 2006 meeting where the changes were adopted after public hearing. No big deal…
Soon after, Anna and I attended the 2006 VOSH Conference and had one of those impromptu but important hallway discussions; we were talking with Ray Davenport, Commissioner of the Virginia Department of Labor, and Glenn Cox, VOSH Director. Mention was made of the inability of OSHA to keep up with technical changes and research-based knowledge in the workplace. This is especially hard for us professionals who must continue to respond to the question, “Where in the OSHA standards does it say I have to do that?” Our VOSH colleagues spoke of how new ARM language might begin to take care of this problem.
Here is §130 of the ARM, which is specific to Construction. The same language is given for General Industry, Agriculture and Maritime standards. All language became effective September 21, 2006.
”The employers shall comply with the manufacturer’s specifications and limitations applicable to the operation, training, use, installation, inspection, testing, repair and maintenance of machinery, vehicles, tools, materials and equipment; unless specifically superseded by a more stringent corresponding requirement in Part 1926…” (See full text at http://www.doli.virginia.gov/publications/pdfs/ARM_2006_booklet.pdf).
In future Circle Safety blogs we’ll discuss specific examples of this knowledge-based approach to safety. This is BIG. Dare I predict that OSHA will come around to this approach?
Jan Thomas, PhD, CSP
President & Consultant
Tags: VOSH
