Occupational (OSHA) and Environmental Hazards/Apartment Management OSHA requirements

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Question
I work for a third party fee management company that specializes in low-income housing. We work in several states, and manage several small apartment complexes in very rural areas.

The apartments have a site manager and a maintenance person who work at the property, and our office has regional managers, accounting staff, etc. that oversee the operations and finances of the property.

We want to make sure that we are compliant with any OSHA regulations, but we are having a difficult time understanding what regulations apply to us. We hire vendors to do most work beyond occasional painting, snow shoveling, and low level maintenance work.

Since the properties are separate "companies" that pay the staff out of their own operating budget, the staff is usually 2 or 3 people. I'm wondering what guidelines I need to follow.

I assume the reporting sections 1904.8 through Section 1904.11 apply, but can you tell me what else would? Thank you very much for your help.

Answer
Subject: Apartment Management OSHA requirements

Question:  work for a third party fee management company that specializes in low-income housing. We work in several states, and manage several small apartment complexes in very rural areas.
    The apartments have a site manager and a maintenance person who work at the property, and our office has regional managers, accounting staff, etc. that oversee the operations and finances of the property.
    We want to make sure that we are compliant with any OSHA regulations, but we are having a difficult time understanding what regulations apply to us. We hire vendors to do most work beyond occasional painting, snow shoveling, and low level maintenance work.
    Since the properties are separate "companies" that pay the staff out of their own operating budget, the staff is usually 2 or 3 people. I'm wondering what guidelines I need to follow.
    I assume the reporting sections 1904.8 through Section 1904.11 apply, but can you tell me what else would? Thank you very much for your help.

Answer: I am not going to be able to assist you as much as you would like for the reason that your question can be very complex and without many specific details any answer I give would be incomplete. Section 1904.8 to 1904.11 will most likely apply but they are only a small part of the record keeping regulations and there are exceptions based on size or other criteria so you need to review the earlier parts of this section of the code to ensure you are in fact a covered employer, etc. I suggest you start by going online and carefully reviewing the entire -
  
  OSHA Recordkeeping Handbook at:

  https://www.osha.gov/recordkeeping/handbook/index.html#1904.2

This may serve to answer some of your current questions and those that may come up in the near future. And if you are like many who start new to this subject - there will be many additional questions.
    You also need to review the list of states you are operating in to determine if your operations in those state are under federal OSHA or under a state OSHA plan (i.e. Oregon, Washington California and others). State plans generally follow the federal but they may adopt rules that are in addition to the federal or in certain circumstances differ. The rest of the safety and health codes under either federal or state control will apply. Just because a requirement is listed in the codes on construction or machine guarding or ship breaking they can be used to cite most places of employment. Thus you need to become familiar with the codes in general so you do not get into situations such as asbestos removal (common in many building products until just a few years ago). Then there is the multitude of state, county and/or city codes in the form of building, fire, life safety, etc that may apply. I would suggest you look for local individuals to help with specific properties. An insurance carrier in many cases have safety and/or health personnel on their staff that can be of assistance or others such as trade associations which may be of assistance.
    If I may be of assistance with specific questions I would be glad to assist so please feel free to ask.

Michael Brown, CSP Retired

Occupational (OSHA) and Environmental Hazards

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Mike Brown CSP Retired

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I specialize in the professional management of occupational safety and health as well as workers` compensation to reduce losses and improve production and address related issues through a comprehensive approach by senior management using proven principals.I worked for over twenty (20) years in the management of occupational safety, health and workers` compensation and safety training (Retired from employment in 1996 due to a stroke, which prevented the extensive travel required).

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