Monthly Archives: November 2012

OHSAS 18000 and ISO 14000

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These standards concern the mechanisms in place to ensure the safety of employees working in a factory and to minimize the environmental affect of said factory. The certification process involves rigorous assessments and perpetual reviews, as well as extensive documentation of the processes you have in place to ensure safety and effective environmental awareness.

The processes necessary to meet these certification requirements are strikingly similar. At their core, these standards are practically indistinguishable; they both require similar documentation and processes. Because of this, one well designed product can help you to meet your regulatory requirements for both standards.

Unfortunately, this product would also have to account for the differences. Some of the major differences between these standards include: employee engagement, the risk reduction hierarchy of 18001, the differing intents, and the implementation of the processes. Without accounting for these differences, a company can not qualify for either of these important certifications.

This is where our Factory Solutions Software is effective. We designed this software to be an all encompassing program to keep your factory compliant in a number of different ways, including a number of key OSHA regulations and OHSAS 18001 and ISO 14000. With our software, you can set your processes, track your changes and evaluations, and ensure employee participation. Our software is all browser based, and can be incorporated with our other services.

We at PFSafety take safety seriously, if you should have any questions about these or any other standards, please contact us. And if you have anything else to add to our brief discussion of these standards, please leave a comment.

HAZWOPER (29CFR1910.120)

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Hazardous waste operations and emergency response (HAZWOPER, for short) guidelines are covered by OSHA standard 1910.120. This standard explains required training for employees dealing with hazardous materials, as well as procedures for the storage, disposal, and operations of all hazard materials and potential accidents with said materials. It explains who may and may not be granted access to such materials, and who is in charge of monitoring the site. Finally, it explains what is required in your business site safety and health plan.

1910.20 gives specific details about what is required in the site safety and health plan. It must include the specifics related to which hazards have been identified, how they were identified, and how these hazards were communicated to the individuals working on site. It also requires that all hazardous sites have an emergency response plan, including applicable state and local authorities where applicable. In addition, specific guidelines are set for monitoring the health of individuals who have been granted access to the site, as well as guidelines for the frequency of medical examinations. Further, the standard goes into detail about what is required of employee trainers, and how often employees must be trained. The standard also covers what personal protective equipment is to be worn. It covers what drums and barrels will be used to store and dispose of the materials, as well as how said containers are to be opened and sealed. The standard additionally discusses at length the proper disposal process for hazardous materials. This is of course, an abridged, and hardly all inclusive, list of what is required; but it does touch on the key points and shows how far reaching this site safety and health plan really is.

Even if you have had a full audit from a third party in the past, and created an in-depth site safety and health plan, it is important to make sure you are keeping adequate records of events and changes. Further, you must ensure that you are still up to code and that no additional risks have presented themselves in the interim. If you have any questions about your current plan, or would like to begin a new plan, please contact us for more information. And if you have any additional information to add, please leave a comment.

Third Party Safety Audits

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Properly managed Third Party Safety Audits can be the difference between a smooth OSHA visit and a disaster. During a safety audit, a certified audit team will provide an independent review of your operations, create a list of best practice recommendations, and form an Action Plan for your company to reach full compliance. In addition, any audits performed by a certified company will comply with all relevant federal and state health inspection requirements.

A third party safety audit is great for customers with a number of different needs. A third party safety audit can help you to: develop an elite safety program, obtain VPP Star/Merit status, comply with your OHSAS 18001 procedures of assessing regulatory compliance,  validate compliance, and a number of other things. While this list is hardly all inclusive, it gives a good idea of the scope of a safety audit.

The reason a safety audit can help customers with so many different needs is that a good third party safety audit will cover a multitude of areas. First and foremost, the safety audit will review any hazardous assessments for specific health and safety programs. This will ensure that your company is properly handling all known hazardous assessments as per the latest OSHA and state standards. Next, an audit team will conduct a complete “wall to wall” safety inspection. This will help your company to find areas of non-compliance, so that you can fix the issues before someone gets hurt unnecessarily. Then, the auditors should review all accident investigations, in an effort to identify areas of potential concern and to fix any problem areas. Finally, an audit team should review employee involvement and safety training, to ensure that the entire team understands their role in keeping the workplace safe.

With all of this data, an audit company can then create an Action Plan to bring your facility up to code. In addition, as per OSHA policy, this Action Plan can be used, should OSHA come to investigate your facility, as a show of good faith, and help you to avoid citations for any incidents found during the audit which you are in the process of fixing.

PFSafety has a certified team of professionals who will ensure that your business is up to code. If you are ready to get serious about safety, contact us so that we can begin developing your audit plan today.

OSHA Compliant Visual Lockout Procedures

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There are many ways to ensure safety and compliance, regarding your written lockout procedures. You can maintain a filing in-house, and become an expert on OSHA standard 1910.147. You can hire a specialist onto your payroll, and pay them to maintain this for you. Or you can hire a company, such as ours, to run this for you. It is, ultimately, your decision, but you must do something.

What these written lockout procedures must cover, is “the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees.” (1917.147 (a)(1)(i)) So, this standard is serious in regards to employee safety. Unfortunately, the standard can be cumbersome, and it can be difficult to keep track of which machines require which written notices, which can often make it difficult to stay in compliance, and can open your facility up to potentially unsafe environments.

The key to creating a solid, compliant, and safe procedure is that it must: “clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance.” (1917.147 (c)(4)(ii)) Further, it must specify steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy; specify steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them; and this must be tested at least annually.

This is but a brief overview of what is required, and how it should be maintained. We at PFSafety can walk you through the entire process, get you up to speed, and help you stay safe and cut costs with annual audits. Click here to learn more about the requirements and the process.

Evacuation Routes (29CFR1910.36)

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Every facility is required to have evacuation plans to meet any one of a series of potential issues. These plans must be capable of evacuating all personnel, through several different means based upon the emergency. OSHA sets guidelines for acceptable safety routes in standard 1910.36.

OSHA requires, first and foremost, that an exit be “permanent,” and the number of available exits must be “adequate.” The permanence requirement is easy, but how do you know if you have enough exits in your evacuation plan? Well, OSHA refers you to: NFPA 101-2009, Life Safety Code, or IFC-2009, International Fire Code. From there, you need to determine the number of employees, the size and occupancy requirements of your building, and the arrangement of your workplace. From there, you need to determine how many exits would be required to evacuate your employees, and how many would be required if one or multiple of those exits are blocked.

Further, you need to examine your actual exits. Are they using fire resistant doors? Are there stairs? Are the exits unlocked from the inside, but not accessible from the outside? Do you use side-hinge doors? What kind of alarm system do you have; will it lock doors if the power fails? If the alarm is not tripped, can the doors still be opened? Are the minimum height and width requirements met by your exits? What about exit windows – do you have any? Are they up to code?

After determining if your exits are acceptable and meet safety guidelines, and you have an adequate number of exits with adequate routes planned out, you still need to ensure that your evacuation routes are printed and properly displayed in your facility. If not, your employees will still be at risk in the event of an emergency. You also need to ensure that your evacuation routes can handle any emergency which may arise, including those caused inside and outside of your workspace.

If you are having difficulty ensuring that your facility is up to code and safe for your employees, take a look at what we at PF Safety offer. If you think a second opinion from a professional firm of experts makes sense for you, contact us and we will get to work making sure you are compliant.

Confined Spaces (29CFR1910.146)

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Confined spaces are an audit nightmare for many companies. There are complicated regulatory requirements as well as complicated practical issues surrounding them. OSHA created standard 1910.146 to help create a safe work environment for employees, and to guide business owners in what should, and should not, be done in the work place.

This standard specifically discusses permit-required confined spaces, helping you to determine if you have any permit-required confined spaces, and if so, what signage is required, what entry conditions are required, how often you need to audit them, and if an attendant is required. It further outlines how you designate access to different people who will be entering this space, and the procedures for required rescue personnel.

This standard also goes into the specifics of what authorized personnel within the confined space must do while in there. It explains the communication requirements, equipment requirements, and notification requirements of both employee and employer. In addition, it discusses the requirements surrounding the physical permit, including the information that should and should not be present on said permit.

Finally, the standard also discusses the role of the attendant. The standard discusses how many spaces an individual attendant can watch, how the attendant is to remain in contact with the entrants, how the attendant is to order an evacuation, what training and knowledge is required of the attendant, and a host of other responsibilities of the attendant.

There is a lot to know when it comes to confined spaces, and it is no wonder that they present such issues to so many businesses. If you have any questions about your confined spaces, check out our confined spaces services. Then, if you are ready to make sure you are up to code, contact us.

Accident Prevention Signs & Tags (OSHA 29CFR1910.145)

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OSHA Standard 1910.145 is one of the most fundamental OSHA safety standards, and is beyond mandatory for you to understand if you want to stay compliant. Here it is. This rule is extremely important and, like most things OSHA, somewhat difficult to fully understand. That’s why we are here, to help you understand these standards and stay in compliance. We dedicate our lives to understanding these codes.

This standard basically clarifies the styles, colors, edges, word usage, and placement of safety signs in your workplace. A sign incorrectly designed or out of place can mean, from a practical sense, an employee getting hurt or being unprepared for a dangerous environment, which can bring OSHA knocking at your door. If OSHA does come knocking, an out of place or misprinted sign can mean a citation or fine, depending on the sign and how egregious the error.

So, what are the specifics of this standard? For starters, make sure your signs are uniform. Beyond that, make sure your signs are in the right places – so, danger signs go where there is immediate danger, caution signs go where there is a need to warn against potential hazards, and biological hazard signs are used when there is either a present or potential presence of a biohazard. Finally, check their borders to make sure they are rounded or blunted, and that you have the correct color scheme. If anything seems incorrect to you, take it down and replace it. With OSHA, it is always better to be safe than sorry.

So, what are you supposed to do if you feel your signs are either incorrect or missing? Check out our printed signs and sleep easy knowing that you have uniform, correctly coded signs for your workplace. If you are worried your signs are out of date and may no longer be up to code, just look them up in our link, and compare them to your own. Trust me, it is far better to replace a few signs now, than have unnecessary injuries in the workplace and citations from OSHA.

Personal Protective Equipment (29CFR1910.132)

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Personal protective equipment is extremely important on the job site. The correct equipment keeps your employees safe and it keeps OSHA out of your hair. But what is the correct equipment, and when should it be used? OSHA answers that with standard 1910.132. This standard explains what is, and is not, required to be worn, where it must be worn, and whether you or your employees are required to maintain it. It also discusses what training is required, and how often you must have your company audited.

Their definitions, however, leave quite a bit of gray area. For instance, it states in 1910.132(c), “all personal protective equipment shall be of safe design and construction for the work to be performed.” Now, this is clearly important for a safe workplace, but how do you know if a piece of equipment is of “safe design and construction?” Well, you can look into what others in your field are using and hope they are using adequate protective gear, you can contact OSHA and hope to get clarification, or you can contact us and we will talk you through your issues.

You must also remember to get your third party safety audits completed, as stated in 1910.132(d)(2). These safety audits are important, as they not only satisfy this requirement, they also allow you to confirm that your workers are safe.

With these questions fresh in your head, take a look over your workplace and make sure everything is up to code. Then, take a look and see when your last third party audit was. If this information is all up to date and you have no questions of code, congratulate yourself. If not, don’t fret, just take a look at our services, then give us a call or shoot us an email and we can help ensure you are OSHA compliant and providing a safe work environment.

Arc Flash and Shock Hazards (NFPA 70E)

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Arc flash hazards are governed by NFPA 70E guidelines and OSHA. Due to the extreme potential dangers of an arc flash situation, there is no leeway given by OSHA or NFPA as it relates to this threat. Correct signage, identification, and borders must be established and regular audits must be performed or your workplace will be unsafe and subject to significant fines.

Many companies only test equipment at 240 V and higher, due to the information released in IEEE 1584. Unfortunately, that only relates to incident energy calculations and does not exempt any companies from the NFPA and OSHA regulations requiring testing of all equipment 50 volts or higher. Testing must also be done on all equipment, regardless of whether it is supplied by a Hazard Risk Category 0 panel. The incorrect assumption that a Hazard Risk Category 0 feed is safe from arc flash hazards has cost many companies substantial sums in penalties from OSHA, and created woefully unsafe environments for employees.

Testing for arc flash hazards can be confusing and unsettling, even for the most experienced safety managers. And with the fluidity of most modern companies, it can be difficult to stay on top of regulatory adherence. But don’t worry, we are here to help. We will test all of your equipment, ensure you are up to code according to NFPA 70E, and create custom signage to make sure you have a safe work environment for your employees. If you have any questions specifically about your company, please contact us.

Welcome

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We are Premier Factory Safety, and this blog has been created as a place to share our experience and expertise in our industry, as well as a place to discuss how we can help you to stay compliant and keep your workplace substantially safer. There is a lot of misinformation about what is, and is not, required by OSHA. There is also a real need for information relating to a safe workplace. We are specialists in this regard, and have decided that we will answer some of the most common questions we get here, and also use this as a place to keep you up to date on any regulatory changes.

We eat, breath, and live safety, with a constant eye on OSHA and its requirements. Please take a look at our site to familiarize yourself with who we are and our products and services. If anything on there is interesting to you, or raises any questions you would like answered, please contact us and we will certainly help you out in every way we can. And who knows, you just may see your question here.

Keep your eyes peeled for our upcoming posts, which will show you how PF Safety can save you from some major OSHA headaches (as well as some non-OSHA headaches from an unsafe workplace).