OSHA Regulation

OSHA Compliance in the Workplace

Employers and joint employer-employee work groups are faced with increasingly difficult demands that workplaces be productive, safe, ergonomically correct, and accommodate the needs of special populations. The sources of these demands range from OSHA compliance to the Americans with Disabilities Act (ADA) requirements.

Dr. Miller himself held a position with Federal OSHA in Washington and was responsible for all OSHA safety standards for a number of years. In this capacity he revised both the General Industry and Construction Occupational Safety Standards (29 CFR Part 1910 and 29 CFR Part 1926). He also worked with the various State divisions to coordinate Federal and State occupational safety requirements. During his tenure in Washington he also assisted in the development of the Material Safety Data Sheet (MSDS) requirements.

Miller Engineering’s experience covers a broad array of workplace concerns, including:

  • Workplace layout for safety and productivity
  • OSHA and MSDS Compliance
  • Manual materials handling safety
  • Cumulative/repetitive trauma disorder analysis
  • Work surface slip/fall prevention
  • Industrial vehicle operations and safety
  • Process machinery accidents
  • Safe maintenance procedures analysis
  • Job Safety Analysis (JSA)

Some of our publications in this occupational safety and health area are listed below:

Occupational Engineering:

  • Lehto, M.R. and Miller, J.M. (2007). “Principles of Prevention: Safety Information,” in Chapter 56, Accident Prevention, ILO Encyclopedia of Occupational Health and Safety, fourth edition, Stellman, J.M. (ed), International Labour Office, Geneva, Switzerland, pp. 56.33-56.38.
  • Lehto, M.R., Nof, S.Y., Bellocci, T. (2003). “Assuring Information Quality in Industrial Enterprises: Experiments in an ERP Environment,” Proceedings of HCI International 2003, 10th International Conference on Human-Computer Interaction, Crete, Greece, Vol. 3, Harris, D., Duffy, V., Smith, M., and Stephanidis, C. (eds), June 22-27, 2003, pp. 654-658.
  • Lehto, M.R. (1996). “Industrial Health and Safety,” McGraw-Hill Encyclopedia of Science and Technology, McGraw-Hill, New York.
  • Miller, J.M. (1982). The Management of Occupational Engineering. In the Handbook of Industrial Engineering. John Wiley.
  • Miller, J.M. and Haas, T. (1980). Health Standards for Workplaces Aboard Inspected Vessels. Federal Register, 45 (29).
  • Miller, J.M. (1972). Commercial Vehicle Occupational Health Hazards (SAE #720264). Society of Automotive Engineers.

OSHA Standards

  • Miller, J.M. (2006). “Standards Reference Bibliography Chapter” in Handbook of Warnings, Michael, Wogalter, ed., Lawrence Erlbaum Associates.
  • Miller, J.M. and Barrett, T. (1980). “Memorandum of Understanding [U.S. Coast Guard and U.S. Department of Labor (OSHA)] : Occupational Safety and Health on Artificial Island, Installations and other Devices on the outer Continental Shelf of the United States.” Federal Register, 45(29).
  • Miller, J.M. (1980, November). “Notice of Proposed Rulemaking for Modification to 29 CFR Part 1907, Laboratory Accreditation.” Federal Register.
  • Miller, J.M. (1980, November). “Response to Advance Notice of Proposed Rulemaking on Unregulated Hazards on the Outer Continental Shelf.” Federal Register.
  • Miller, J.M. and Bingham, E. (1979). “Response to Advanced Notice of Proposed Rule Making on Unregulated Hazards on the Outer Continental Shelf.” Federal Register, September 20, Docket CG79-073.
  • Miller, J.M. (1979, February). “Verticalization Package of OSHA 1910/1926 Safety and Health Standards.” Federal Register.
  • Miller, J.M. and Bingham, E. (1978, February). “What’s Ahead for OSHA Standards,” Invited paper for the Greater New York Safety Council and the New Jersey Chamber of Commerce, New York.
  • Miller, J.M. and Bingham, E. (1977, October). “Priorities for Future OSHA Standards Activities.” Invited paper by the National Safety Council for the National Safety Congress, Chicago.

Chemical/Toxic Exposures (MSDS)

  • Miller, J.M. (2007). “Hazard Communication Compliance”, in Safety Engineering Handbook, American Society of Safety Engineers.
  • Lehto, M.R., House, T.E. and Papastavrou, J.D. (2000). “Interpretation of Fuzzy Qualifiers by Chemical Workers,” International Journal of Cognitive Ergonomics, Vol. 4, No. 1, pp. 73-88.
  • Lehto, M.R. (1998).“The Influence of Chemical Warning Label Content and Format on Information Retrieval Speed and Accuracy,”Journal of Safety Research, Vol. 29, No. 1, pp.1-14.
  • Lehto, M.R. and House, T.E. (1997). “Evaluation of the Comprehension of Hazard Communication Phrases by Chemical Workers,” International Ergonomics Association 13th Triennial Congress, Tampere, Finland.
  • Miller, J.M., Chaffin, D., Dinman, B., Smith, R. and Zontine, D. (1975). Psychomotor and Neuromuscular Changes in Workers Exposed to Inorganic Mercury. Journal of the American Industrial Hygiene Association, October.
  • Miller, J.M. and Chaffin, D. (1973). Behavioral and Neurological Evaluation of Workers Exposed to Inorganic Mercury. (NIOSH Contract #5T01-0N00161-02).
  • Miller, J.M., Chaffin, D., Dinman, B., Smith, R. and Zontine, D. (1973). An Evaluation of the Effects of Chronic Mercury Exposures on EMG and Psychomotor Functions (Final Report, NIOSH Contract #5T01-0N00161-02).

Commercial Vehicles Occupational Safety and Health Hazards

Dr. Miller took an early interest in the safety and health considerations of the commercial vehicle operator. These interests and concerns were initially expressed in the following articles. They include discussions of hazards such as slip and falls, driver fatigue and driving hours, carbon monoxide exposure, vibration health effects, visibility limitations and reaction time in emergency situations.

  • Miller, J.M. with Rhoades, T.P. (1990). Revisions of TMC Recommended Practice RP-404 ‘Truck and Truck Tractor Access Systems’. 1989 SAE Transactions: Journal of Commercial Vehicles, 98 (2).
  • Miller, J.M. with Rhoades, T.P. (1989). Revisions of TMC Recommended Practice RP-404 ‘Truck and Truck Tractor Access Systems’. (SAE Technical Paper Series #892523).
  • Rhoades, T.P. (1988, June). Proposed Revisions of TMC RP-404. Presented to TMC Study Groups, Tucson, AZ.
  • Rhoades, T.P. (1986, June). Use of the Transportable Force Plate Measurement System. Presented to the Heavy Truck Design Analysis Group, Ford Motor, Co.
  • Miller, J.M. (1978, August). Appropriateness of Standards for Commercial Vehicle Cab Interior Design. Response to a Federal Register Docket, submitted to U.S. Department of Transportation on behalf of the International Brotherhood of Teamsters.
  • Miller, J.M. (1976). Efforts To Reduce Truck and Bus Operator Hazards. Human Factors, 18 (6), 533-5.
  • Miller, J.M. (1972). Commercial Vehicle Occupational Health Hazards (SAE #720264). Society of Automotive Engineers.

The Three-Point System for Effective Climbing, Egress, and Ingress

Climbing/slip and fall analyses have been a major strength of Miller Engineering in relation to truck/tractor systems. Both experimental and design work has been conducted. Traditional and cabover engine models have been evaluated and methodologies have been developed to both analyze and depict truck/tractor climbing systems. Miller Engineering has fully computerized data collections which utilize force plates to analyze choices of step surfaces, sole-step interactions, human gait, and effectiveness of 3-point climbing systems. We have also participated in the design of standards relative to the egress and ingress issues. The following are a few of our articles relating to this topic:

  • Miller, J.M. with Rhoades, T.P. (1992). Methods Used On Atypical Climbing Systems, In S. Kumar (Ed.), Advances in Industrial Ergonomics and Safety IV, London: Taylor & Francis.
  • Miller, J.M. with Rhoades, T.P. (1990). Revisions of TMC Recommended Practice RP-404 ‘Truck and Truck Tractor Access Systems’. 1989 SAE Transactions: Journal of Commercial Vehicles, 98 (2).
  • Miller, J.M. with Rhoades, T.P. (1989). Revisions of TMC Recommended Practice RP-404 ‘Truck and Truck Tractor Access Systems’. (SAE Technical Paper Series #892523).
  • Rhoades, T.P. (1988, June). Proposed Revisions of TMC RP-404. Presented to TMC Study Groups, Tucson, AZ.
  • Rhoades, T.P. (1986, June). Use of the Transportable Force Plate Measurement System. Presented to the Heavy Truck Design Analysis Group, Ford Motor, Co.

Workers Compensation

  • Miller, J.M. and Herrin, G. (1978, January). Relation of Workers Compensation Data to National OSHA Priorities. Invited paper for the Bureau of Labor Statistics, Memphis, TN.

Work Measurement

  • Lehto, M.R., Sharit, J., and Salvendy, G. (1991). “The Application of Cognitive Simulation Techniques to Work Measurement and Methods Analysis of Production Control Tasks,” International Journal of Production Research, Vol. 29, No. 8, pp. 1565-1586.
  • Miller, J.M. (1974). Work Measurement as a Tool in Teaching Dental Students and Scheduling Simultaneous Patients. In Proceedings of the American Institute of Industrial Engineers 25th Annual Conference, New Orleans.