Monthly Archives: May 2013

Tracking Lockout Tagout Changes

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One of the most important OSHA standards to ensure adherence to is Standard 1910.147. This standard governs lockout tagout procedures, which are extremely difficult to comply with and even more difficult to maintain.  Every time a piece of machinery is changed, a company procedure is updated, or an employee is moved, the lockout tagout library needs to be updated, and tracking these changes can create a huge problem for many business owners and safety teams.

Fortunately, software has been created which allows safety professionals to quickly and effectively track and manage all lockout tagout changes. PF Safety has created a fully scalable, fully customizable software for lockout tagout called Factory Solutions Software, which comes preloaded with a database of procedure libraries that can be adapted to meet your needs. And best of all, this software can be accessed from anywhere internet is available, as the software is 100% web based.

Once a procedure library is created with this software, it is easy to identify energy isolation points and create and place the required placards. And as your business changes, it is as simple as keying the changes into the program to uncover new isolation points and to determine where new placards should go. Factory Solutions Software helps business owners ensure their company is always compliant with lockout tagout procedures, regardless of changes going on.

If you have any questions about the specifics of our lockout tagout monitoring software, please contact us so that we can discuss whether or not it makes sense for your business. And if you have anything to add about tracking lockout tagout changes, please leave a comment.

Personal Protective Equipment Saves Lives

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Acting as a last line of defense against injury for employees, personal protect equipment is often the only thing protecting employees from dangerous equipment, faulty systems, mislabeled tools, and themselves. No safety guideline can prevent employees from all faulty machinery or from human error, but properly utilized personal protective equipment can lessen the damage in an emergency situation, and can save an employee’s life in many situations.

Unlike normal safety procedures which generally involve external devices to detect or deter accidents and faults, personal protective equipment is generally worn by the person at risk. And while a system can shut down, a facility can lose power, and a label can fall off, basic personal protective equipment like gloves, body suits, helmets, or glasses are generally not susceptible to these same worries. And as helpful as all of these systems and procedures are, if an employee misuses a tool or enters an area by accident, it can become easy to trigger an event which falls outside of the normal scope of a safety plan, leaving the employee at risk.

It is in these situations that people are most at risk, because they are left alone with no systems in place to protect them. And while many employees put themselves in these situations on a daily basis, few are ever actually injured or killed when they are wearing appropriate personal protective equipment. This equipment is easily the most important safety mechanism available, as it protects the employee at the time of an accident, after the failsafes have all failed.

So if you have not reviewed your personal protective equipment recently, and are concerned you could be using outdated or damaged equipment, please contact us so that we can review your procedures and equipment to determine if there are any violations or unsafe practices. Should you have anything to add about the importance of personal protective equipment, please leave a comment.

Communicating Potential Hazards from Hazardous Substances

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In May of 2012, there were updates made to OSHA Standard 1910.1200, which regulates the communication of potential hazards associated with hazardous materials. The updates were made to bring the OSHA standard in line with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals, Revision 3. And while many standards are updated every year, this was the first major update to this standard in nearly 20 years; the first since a major update in 1994. So if your business deals in hazardous materials but your safety team has not reviewed and updated this section of the safety and health management system since last May, there is a good chance your company is no longer compliant, which means it is in danger of potential fines and your employees are potentially at risk.

A company in any industry which deals in hazardous materials, including laboratories, wholesalers, manufacturers, importers, warehouses, and retail stores, just to name a few, needs to ensure that it is up to code in relation to Standard 1910.1200. This standard specifies how to identify and classify hazardous materials and how to communicate this information to employees. It also covers protective communications to employees. This standard is very clear about what is – and is not – a hazardous material, and what preventative steps must be taken to ensure all details of the material are communicated to anyone who might come in contact with the material.

If you have not reviewed your procedures on hazard communication since last May, it is important to have your procedures audited to ensure your company is still up to code. If you would like help in this task, or would like some guidance on how to properly label any new products you have begun working with, please contact us. Should you have any general questions about hazard communication, or would like to add anything else about this standard, please leave a comment.

OSHA 29CFR1910.106 Flammable and Combustible Liquids

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In today’s world of chemicals, flammable and combustible liquids pose a grave fire risk that threatens workers safety and the workplace. Because flammable and combustible liquids have become ubiquitous in the workplace and their potential hazard is so high, understanding those liquids is essential in the prevention and control of their hazards.

OSHA 29CFR1910.106 applies to the handling, storage and use of flammable and combustible liquids. The basis of the standard is NFPA publication 30. OSHA, a division of the Department of Labor (DOL), considered NFPA as a primary source for best practices as it relates to flammable and combustible liquids.

The National Fire Protection Association (NFPA) released a report, February 2012, entitled “The total cost of fire in the united states” where they reported that the U.S. spent an estimated $331 billion on fire in 2009. In a previous report NFPA estimated 1,400 fires occurred annually between 2002 and 2005 where flammable liquids were the major contributor for the fire.

In order to understand flammable and combustible liquids, it’s important to understand the terminology used to define them and their potential hazards. It’s also important to understand that the flammable and combustible liquids themselves do not burn. It’s their vapor mixed with air, within a specific range, that burns. Since the flash point determines the liquids ability to generate vapor, flash point became the basis for classification and identification of flammable and combustible liquids.

The flash point characterizes the fire hazards of liquids. The lower the flash point the lower the temperature at which the liquid gives off vapor and the more flammable the liquid is. For example, the flash point for gasoline is –45 deg. F, which means that the liquid gives off vapor at room temperature and much lower and therefore it’s highly flammable.

Flash point is defined as the minimum temperature at which a liquid gives off sufficient vapor that can form an ignitable mixture with air. At its flash point temperature, the liquid vapor flashes when lit in an open container. Flash point shouldn’t be mixed up with fire point, which is normally 5 to 10 degrees higher than the flash point. At its fire point temperature, the liquid vapor sustains fire when lit in an open container.

OSHA defines flammable liquid as any liquid having a flash point below 100 degrees Fahrenheit (deg. F). Flammable liquids are known as Class I liquids and divided into three sub-classes; class IA, class IB and class IC depending on their flash point temperature.

Combustible liquids are defined as any liquid having a flash point at or above 100 deg. F and divided into two classes; Class II and class III. In turn, class III is divided into two sub-classes; class IIIA and class IIIB liquids depending on their flash point temperature.

Too much vapor to air will make the mixture too rich and too little vapor to air will make the mixture too lean to burn. It’s the proper mixture of vapor to air ratio that gives rise to the fire risk. The flammable range is the limit between the minimum concentration and the maximum concentration of flammable vapor in air, in which a flash will occur in the liquid if ignited. Those limits are referred to as the lower and upper flammable limits (LFL or UFL). The vapor mixture below its LFL or above its UFL will not burn.

Because of their high potential for fire hazards, flammable and combustible liquids should be handled, used and stored with great caution. Metal containers and portable tanks used for flammable liquids should be made of proper material and should be properly vented. In most instances, grounding of containers while filling tanks is a must to avoid accidental static charge sparks. Storing of flammable liquids should be done in accordance with the OSHA standard. Suitable fire control devices, hoses of fire extinguishers, should be available at locations where flammable or combustible liquids are stored.

Complying with OSHA 1910.106 is a good way to ensure safety and prevent accidental fires.

Evacuation Route Requirements and Maintenance

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In the event of a serious emergency, a clearly defined and understood evacuation plan is often the only thing which prevents a disaster from becoming a tragedy. Evacuation plans save lives; understanding where to go in various circumstances, and having clear paths to exits allow employees to safely exit the building, even in a panic. A poorly designed evacuation route, meanwhile, can cause unnecessary harm to employees and even lead to needless fatalities. This is why OSHA takes means of egress so seriously, and is why they enacted Standard 1910.36 and Standard 1910.37.

Standard 1910.36 covers the basic requirements for the design and construction of exit routes. It explains requirements for the exit itself, stating that the exit must be permanent, fireproof, unlocked, lead directly outside, and that the number of openings into an exit are to be limited. It also discusses what is considered an “adequate” number of exit routes, and how to determine if a facility meets this minimum requirement. Finally, this standard also specifies height and width requirements for the evacuation route, as well as the specifications for the exit itself, including the hinges required, the height and width, and the appropriate locking mechanisms.

Standard 1910.37 covers the maintenance, safeguards, and operations features for exit routes. It explains that exit routes must have adequate lighting, must be unobstructed, that exit signs must be clearly labeled and illuminated, that alarm systems must always be operable, and discusses the steps to take during construction and repairs to ensure the exit route remains operational.

If you have any concerns that your evacuation routes are not up to these standards, or if you feel they are not prominently displayed in the proper locations, please contact us. And if you have anything to add about evacuation routes, please leave a comment.

Arc Flash Hazards

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Arc flash analysis is another one of those extremely serious hazards which are all too often overlooked by safety teams. Part of the reason for this is the complexity of the rules regulating arc flash, and part of the reason is the fact that OSHA does not directly regulate it. Instead, OSHA relies on NFPA 70E to set their requirements. So, if you are just setting your safety plan based upon OSHA standards which are pertinent to your business, it is very possibly to completely bypass the arc flash requirements.

First and foremost, when establishing arc flash procedures, it is crucial to at least consult with a professional firm which has experience in this arena. Arc flash rules can get extremely complicated, especially for larger companies with more machines, and shortcut guides can often lead to errors. For instance, IEEE 1584 is a common guide used to calculate arc flash hazards, but it is incomplete in several ways and many companies which use only IEEE 1584 guidelines are not actually safe or compliant.

After establishing where there are arc flash hazards, it is important to put proper signage in place. These signs warn employees of the dangers of the machines, and explain how to prevent injury. Without proper signage, arc flash analysis does nothing to help protect employees, and it is important to make sure the correct signs with the correct information go in the correct places.

If you have any questions about arc flash analysis, would like to establish formal procedures for your workplace, or would like to have your current procedures reviewed, please contact us so that we can help you. If you have anything to add about arc flash dangers, please leave a comment.

Third Party Lockout Tagout Monitoring

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Lockout tagout accidents are a real threat to employees at any business which has a lockout tagout risk. The only way an employer can help protect employees from danger is through thorough and accurate lockout tagout procedures. These procedures must be maintained and regularly updated based upon the changes on the work site or the changes to the laws as determined in Standard 1910.147, which OSHA implemented to govern lockout tagout procedures.

The fines associated with a lockout tagout issue are quite steep due to the serious nature of lockout tagout errors. The potential risk to employees is also quite serious. Lockout tagout injuries can result in critical injuries or death. It is for this reason that many businesses turn to lockout tagout experts to manage their lockout tagout needs, including updating and ensuring the accuracy of their procedures.

Beyond simply creating and maintaining centralized procedures, a third party lockout tagout monitoring company can also ensure that these procedures are printed up and posted where appropriate. The procedures themselves do little if the staff is not properly made aware of them. The printing of the procedures is also more complicated than many business owners first realize, there are specific rules regarding the size, colors, and information included in lockout tagout procedure posted notifications.

If you have any questions about lockout tagout monitoring, and why a third party might be a good option for you, please contact us. And if you have anything to add about the many benefits of third party lockout tagout monitoring, please leave a comment.

Medical Services and First Aid

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Standard 1910.151 was created by OSHA as a way to ensure employees have access to basic first aid supplies and required medical help, should they be injured on the job. Basic first aid supplies can help to prevent a minor injury from becoming serious, and a serious injury from become life threatening. And in any medical event, access to help from qualified medical professionals can severely increase an employee’s chance of a full and speedy recovery.

The primary medical response should come from local first responders who can bring an injured person to a local infirmary, clinic, or hospital in near proximity to the workplace. If there is no readily available infirmary, clinic, or hospital, then a company is required to train an individual who can properly use first aid supplies. Regardless of the need for this individual, a company is always required to have “adequate” first aid supplies readily available, should they be needed.

As with many other OSHA Standards, 1910.151 leaves a lot of room for interpretation. For instance, what constitutes “basic first aid supplies?” And how many of these items would be enough? In order answer these questions properly and to make sure that your business is appropriately up to code, we usually recommend a third party safety audit. With an audit, an auditor can review your current processes and watch your team, to ensure that your process is adequate and your team is properly following it.

For more information on OSHA Standard 1910.151, please contact us. If you have anything to add about medical services and first aid, please leave a comment.

The Benefits of a Third Party Safety Audit

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There are a number of benefits to an organization which hires a professional safety firm to audit its facility. These benefits include granting a company access to years of experience in the safety field, having a second set of eyes review safety paperwork to make sure there is not a missed opportunity to improve efficiency and efficacy, and receiving an action plan which can be used to bring an organization up to code if there are any deficiencies.

Experience is one of the most important factors to consider when hiring a third party safety auditor. Many of OSHA’s policies have room for interpretation; if you hire an inexperienced auditor, he or she may never have been in that situation before, meaning they are not able to draw from previous experiences when making decisions. It is also important to consider the relevance of related experience, to make sure the auditing firm has experience in your line of work.

As with anything in life, it is always a good idea to have someone review your safety plans to ensure they are up to code, and that nothing has changed unbeknownst to the company’s management team. Should there be any issues with the current safety plan in place, a professional auditor will develop an action plan to help bring the company back up to code.

If you have any questions about third party safety audits, please contact us. And if you have anything to add about third party safety audits, leave a comment.

Properly Identifying Piping (ANSI/ASME A13.1)

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The ANSI/ASME A13.1 pipe labeling system was created to help employers and employees quickly and effectively identify what materials are flowing through a pipe, and in what direction those materials are flowing. This is important for day to day work activities, as it is always important to understand what you employees are working around, especially if a leak or other piping issue should arise. But it is critically important in the event of a serious emergency, as it can help employees determine which ways they should, and should not, go if there are broken pipes in their way. It also makes the job of first responders and other disaster personnel easier, as they, too, can quickly identify what substances have leaked, or are of potential concern in various parts of your work place. This simple, universal labeling system can save lives, and is of extreme importance to workplace safety.

The system itself is relatively easy to use. It is a color coded system consisting of 10 color schemes. The scheme is the combination of the color of the writing and the color of the background upon which the writing rests. Many of these color schemes have preset meanings, allowing anyone with a knowledge of this system to quickly identify the materials flowing in your pipes. For the few which are allowed to be company specific, it is important to note these schemes in your safety and health management system as well as your emergency action plan, so that they can be conveyed to anybody who needs that information.

The system also identifies the sizes and types of labels required for different sized pipes. The guidelines for the sizes and lettering, as well as the color schemes, changed in 2007. If you have not yet incorporated the ANSI/ASME A13.1 labeling system, or if you have not updated since the 2007 changes, it might be time to do so.

If you would like more information on this labeling system and how it can impact your business, please contact us. And if you have anything to add about ANSI/ASME A13.1, please leave a comment.