OSHA requirements can be found at this link.
When you read OSHA bump test requirements regarding gas detection units, it can be a little “confusing” (their word).
Scroll to the heading “When to Perform a Bump Test and When to Perform a Full Calibration”
You will see that OSHA admits that there is confusion in this area. They recommend performing a bump test “before each day’s use”. We at CalGasWarehouse, along with
Gasco Affiliates, recommend a bump test before EACH use. Sensors can go bad at any time and the only surefire way of knowing – perform the bump test! The industry average is a bump test once every 52 days! We equate that to inspecting your parachute, once every 52 jumps. That’s insane, potentially deadly, and no jumper would take that risk! You shouldn’t take the risk with a gas detection unit either!
Now, we have established OSHA’s recommendation on bump testing..or have we? If you scroll back up to OSHA’s Introduction (from the actual regulation), you will find this – “verifying the operational capability of these instruments before each day’s use, with additional testing conducted as necessary”. If you bump test at the beginning of the day and use the monitor for a 3rd time without bump testing and an employee gets sick or worse, its fatal. What part of this regulation do you think OSHA is going to look at? You tell them you bump tested at the beginning of the day and they ask “did you perform the additional testing as necessary?”. We wouldn’t want to be on the other end of that question! Our philosophy is to be proactive, instead of reactive, especially when peoples’ lives are at risk. The ONLY way to avoid the confusion of the regulation, and ensure safety, is to have all employees with detection units perform a bump test prior to EACH use. It HAS to become the culture and routine. We believe it is going to be mandated based on the chatter we hear, get a head start! You may want to keep a log with each unit and write date and time of the bump test. It already should have a file in the office with a calibration certificate. Have your employees or safety director turn it in weekly or monthly, depending on the frequency of use. Add a label to each unit – “Bumped?”. Be creative but change the culture and the behavior! A test every 52 days is a recipe for disaster. #Gasco Affiliates posted on LinkedIn and equated it to the original seat belt law. The mindset and culture was changed and now a majority of people grab the seat belt before the car is in drive. That is the mindset we need to create around bump tests!
We tell people in our store all of the time – Safety is an investment and should be a budgeted item (you would be amazed how many panic purchases we experience). We also tell them safety is much less expensive on the front end than it is on the back end (potentially being sued for a fatality, OR, fines from OSHA for not following regulations). What do you think is more expensive, a bump gas cylinder or OSHA fines and/or a wrongful death lawsuit?
We hope that you will consider the regulation, but more importantly, consider the risk to your employees and consider our advice on bump testing. Jobs requiring gas detection units are dangerous and they can be, and have been, deadly!
Until next time, stay educated and stay safe!