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Industry Focus

Manufacturing

OSHA General Industry compliance and EHS program development for manufacturing operations.

LOTO (1910.147) is cited in over 50% of manufacturing facility inspections

Manufacturing plants operate under OSHA 29 CFR 1910 — the General Industry Standard — not the construction standard most companies associate with OSHA. The requirements are extensive: written programs for lockout/tagout, confined space entry, and hazard communication; machine guarding on every piece of production equipment; documented training records for every exposed employee.

The gap between what OSHA 1910 requires and what most mid-size manufacturers actually have in place is where citations happen. Greenberg Safety provides manufacturing safety consulting that starts with a compliance gap audit and works through written program development, employee training, and ongoing EHS support for facilities that need consistent oversight without the cost of a full-time hire.

Lockout/Tagout (1910.147)

Energy control procedures must be written specifically for each piece of equipment, not generic. Authorized employees must be trained on each procedure, and periodic LOTO program inspections are required annually.

Machine Guarding (1910.212)

Every machine with rotating parts, flying chips, or point-of-operation hazards must have guards adequate to prevent contact. Nip points, in-running rolls, and shear points all have specific guarding requirements.

Hazard Communication (1910.1200)

A written HazCom program, SDS for every hazardous chemical accessible to employees on every shift, labeled containers, and documented training are all required. GHS alignment is mandatory.

Permit-Required Confined Spaces (1910.146)

Tanks, vessels, hoppers, and other confined spaces require a written permit space program, trained entry supervisors and attendants, atmospheric testing equipment, and rescue procedures.

Emergency Action Plans (1910.38)

Facilities with 10 or more employees must have a written EAP covering evacuation routes, employee accounting, alarm systems, and designated roles — and employees must be trained on it.

Personal Protective Equipment (1910.132)

PPE selection must be based on a documented hazard assessment for each job task. Relying on general PPE without written assessments is a citation waiting to happen during an OSHA inspection.

  • OSHA 29 CFR 1910 (General Industry Standards)
  • 1910.147 — Control of Hazardous Energy (Lockout/Tagout)
  • 1910.212 — Machine Guarding
  • 1910.1200 — Hazard Communication (GHS)
  • 1910.146 — Permit-Required Confined Spaces
  • 1910.134 — Respiratory Protection
  • 1910.132–138 — Personal Protective Equipment
  • 1910.38 — Emergency Action Plans
  • ANSI/ASSE Z244.1 — Lockout/Tagout