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Horizontal and Vertical Standards – What’s the Difference?

- October 9, 2017 by Steve Medellin (View all posts by Steve)

I was told once that if an OSHA Compliance Safety & Health Officer (CSHO) cited me in the wrong book (for example a construction company cited in 29 CFR 1910 General Industry) that the citation would be thrown out. Is this correct?  The answer – it depends!

It depends whether the standard cited is a horizontal and/or a vertical standard. So, what is the difference?

Horizontal Standard

Let’s say the example above is a citation for Hazard Communication, and the CSHO cited 1910.1200(f)(9).  The employer shall not remove or deface existing labels on incoming containers of hazardous chemicals unless the container is immediately marked with the required information. Then the CSHO would be in his right to cite this General Industry standard because it is a horizontal standard.  A horizontal standard is one that is ‘general’, or ‘across the board’.  Another example of a horizontal standard is CFR 1910.178 Industrial Trucks, also known as forklifts.

Vertical Standard

However, if the CSHO is on a construction site and observes that an ironworker did not tie off while connecting iron 25 feet up without fall protection, and he were to cite the iron worker’s company under Walking/Working surfaces in 29 CFR 1910 – the CSHO would be wrong to do so.  Or, if the CSHO were to go in the correct book, 29 CFR 1926 of the construction standards, and cite Subpart M, Fall Protection – he would also be wrong.  That is because the 29 CFR 1926 has a subsection R which would be a vertical standard because it only applies to steel erection and ironworkers.

Vertical standards are only applicable to particular industries.  When reading the scope of the standard for Subpart R in 29 CFR 1926, it specifies which industry the standard covers, and it defines the operations which would be considered for that particular industry.

Implications

In conclusion, just because you are responsible for safety for an organization that falls into a construction related trade, it does not mean the General Industry book is worthless or not relevant to your operations, as there are horizontal standards that may have implications for your company.

 
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