OSHA has set certain limitations on the use of the general duty clause. In fact, Let’s take a brief look at the applicability and purpose of the General Duty Clause, how it differs from the RMP Rule, and the steps employers need to take to maintain compliance and ensure workplace safety.The RMP Rule requires owners and operators of any “stationary source” who store, process or otherwise use At a basic level, EPA requires a facility's RMP to include:RMP regulations establish a substantial level of protection for workers, communities and the environment against chemical-related emergencies, yet there are serious risks that RMP regulations fail to address. VelocityEHS’ VelocityEHS can even help you provide your workers with immediate access to critical chemical safety and response resources during a chemical spill or release. VelocityEHS offers a comprehensive suite of chemical safety solutions and services to help you ensure compliance with a multitude of environmental, health and safety requirements, including EPA’s RMP Rule and General Duty Clause.It all starts with identifying the hazardous chemicals present in your workplace, and knowing which of those are regulated by EPA’s RMP Rule, General Duty Clause, EPCRA and other regulations. Employers that fail to comply with OSHA’s guidance and the CDC’s recommendations will be at a higher risk of General Duty Clause citations if an employee experiences a COVID-19 work-related infection. Fortunately, it doesn’t have to be. How OSHA Inspectors Cite The General Duty Clause. To see how we can help you reach your unique chemical safety and compliance needs, This site requires Javascript to be enabled for full functionality. In fact, EPA’s General Duty Clause has an even broader reach than the RMP Rule because it includes “any other extremely hazardous substance” in the list of chemical hazards that must be addressed. For example, OSHA historically has utilized the General Duty Clause in workplace violence situations. The employer inability to provide for an improved or an ergonomic workstation where lengthy sitting time is involved which include garment or textile sewing companies and computers workstation can be regarded as the violation of the General Duty Clause.Example of a Violation of the General Duty Clause (Section 5(a)(1) of the OSH Act) For instance, if facility managers learn that a water-based fire suppression system was installed in areas where water-reactive chemicals are used, they would need to address that as a hazardous condition – perhaps by replacing the system with one compatible with water-reactive chemicals.Looking at the big picture, the best general course of action is to perform a comprehensive hazard assessment for all hazardous chemicals in your workplace, implement appropriate engineering controls and other hazard elimination strategies necessary to prevent releases of those chemicals, and develop an effective emergency action plan that details what specific measures you will take to respond to potential releases.Looking for more information about what inspectors might be looking for if they come to your facility? © Copyright 2019 VelocityEHS. If the hazard violates a specific OSHA standard (like, for example, there are hazardous chemicals that are not labeled as required by the Hazard Communication standard), the inspector will cite the employer for violating that standard. Unlimited SDS Searches, 5 FREE Downloads, No Credit Card During an OSHA inspection, the inspector will walk-around the work area and look for hazards. Both are established under the Accidental Release Prevention requirements in Section 112(r) of the Clean Air Act, and while the General Duty Clause imposes many of the same chemical safety requirements as the RMP Rule, many covered facilities unfortunately overlook these requirements. Specifically, RMP requirements do not cover facilities which use listed hazardous substances For example, the threshold quantity for carbonic dichloride, a chemical used in the manufacture of pesticides and pharmaceuticals, is 500 pounds.