Monthly Archives: September 2013

Machine Guards

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In response to the obvious risks associated with worksite machinery, OSHA created Standard 1910.212. This standard regulates what types of machine guarding are required for the many types of machines in use today. Any guards used should not, in themselves, be hazardous.

The types of hazards which must be guarded against are: “those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks,” among others. So what you need to keep in mind when ensuring you have effective guards in place, is that the regulation covers a lot of territory.

Any machine guarding used in your facility should be attached to the machine, when at all possible. This ensures the best protection for employees. When it is impossible to affix the guarding to the machine, then it is to be secured elsewhere.

The most common machines which require point of operation guarding are as follows: guillotine cutters, shears, alligator shears, power presses, milling machines, power saws, and jointers. If your facility uses any of these devices and you do not have a specific plan in place for their guarding, consider hiring a professional consulting firm to help you. The first step to consider is a full third party audit to ensure there are no other potential issues with your safety plan.

If you have any questions about machine guards, and when you need them, please contact us so that we can help. If you have anything to add about the importance of utilizing machine guards, please leave a comment.

OSHA Lockout Tagout Procedures

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The creation and monitoring of lockout tagout procedures should be of critical importance to any company with the potential for a lockout tagout issue. Lockout tagout incidents can, and usually are, deadly. So, proper lockout tagout procedures are necessary to protect employees. And, because of the seriousness of injuries associated with lockout tagout, OSHA takes these procedures very seriously, frequently citing companies for violations, and assessing large fines for noncompliance.

So in order to protect your employees and your bottom line, it is important to properly establish your lockout tagout procedures and to properly monitor them, documenting changes, as needed. Anyone who has ever attempted to establish new lockout tagout procedures can tell you how time consuming and difficult the initial procedures can be to create. For this reason, many companies hire a qualified third party to assist in the creation of lockout tagout procedures.

But as hard as it is to create these procedures, it can often be harder to monitor them. It is difficult to come up with a cost effective process for monitoring each movement and change in relation to the equipment and personnel using the equipment. Fortunately, there is now web-based computer software which is fully scalable and fully customizable, which tracks your lockout tagout for you. This software acts as a strong safeguard against workplace injuries and OSHA citations, by ensuring your company is up to date on all lockout tagout changes, and that your employees are following the appropriate lockout tagout procedures.

If you have any questions about lockout tagout, please contact us. And if you have anything to add about the importance of instituting adequate lockout tagout procedures, please leave a comment.

TSCA and HAZWOPER

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The Toxic Substance Control Act (TSCA) was signed into law in 1976. It was the end result of six years of negotiations, and does little to actually help protect people. This law regulates which hazardous chemicals may and may not be used. It is the only law which governs the legality of specific substances, and it places the entire burden of testing on the Environmental Protection Agency (EPA).

To make matters worse, there is only a 90 day window for the EPA to determine if a hazardous chemical poses “unreasonable risk of injury to health or the environment.” If the EPA cannot test the substance, review the data, and come up with conclusive evidence that a substance should be banned during that time, it will, instead, be released for mass production. This system does not work; in the 23 years since 1990, less than 200 of the 62,000 chemicals currently in use were tested by the EPA. Of those chemicals, only 5 have been banned.

Obviously, something more had to be done. For these reasons, OSHA created Standard 1910.120, Hazardous Waste Operations and Emergency Response (HAZWOPER). OSHA has no oversight to test or ban specific chemicals, so instead OSHA created this standard to regulate the handling, transportation, and destruction of these substances. Closely following this standard is the only way to ensure employee safety in relation to the many dangerous substances used on a daily basis all across the country which have never truly been tested for safety.

If your company uses any hazardous chemicals, it is imperative you ensure that your procedures follow the HAZWOPER guidelines perfectly. Should you have any questions about the standard or about your procedures, please contact us so that we can help you. If you have anything to add about TSCA or HAZWOPER, please leave a comment.

Do I Need a Third Party Safety Audit?

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When potential clients reach out to us to discuss a third party safety audit, the conversation almost always comes to the question of “need.” The clients have either had an incident at their workplace and feel they have adequately resolved the issue, and thus are unsure if they “need” an audit, or they were unable to resolve the issue and understand they need help, but are unsure if an audit is the appropriate step, or they have not had any incidents yet, but are concerned for the future.

And in each of these situations, the answer is usually that yes, you do need a third party safety audit. If you are in a situation where there has been a workplace incident relating to a safety practice, your first step should always be to consult a professional firm that specializes in occupational health and safety. Even if you think you have the situation under control, you want to be able to prove that you did everything in your power to remedy the situation correctly.

If you are simply concerned about the safety of your workplace, you need to think about why you were concerned in the first place. Most people who reach out to a third party safety auditing firm do not do so for no reason. And if there is something at your facility which you feel needs to be looked over, it is always a good idea to do so.

If you have any questions about third party safety audits and whether or not your company needs one, please contact us. And if you have anything to add about the importance of third party safety audits, please leave a comment.

Emergency Action Plans Save Lives

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Emergency action plans are important for businesses of all sizes. They help to ensure that all employees are safe and accounted for in an emergency situation, and can help with business continuity after an emergency. And while it is important for every employer to have an emergency action plan in place for these reasons, it is also important to know that it is an OSHA requirement. OSHA regulates emergency action plans with Standard 1910.38.

Standard 1910.38 basically dictates that an emergency action plan must be in place, must be available to employees in writing, and must have specific procedures in place for the handling of emergency situations. These plans must include how to evacuate, how to notify the proper authorities, how to account for personnel after evacuation, and how to account for anyone who will remain in the building.

But beyond the basic details, it is important to remember the purpose of the emergency action plan. It is not a document that should be written up and forgotten about; emergency action plans can and do save lives. If a fire breaks out in a plant, this document has the predetermined steps to get employees out safely. And when you look at the recent disasters in Colorado and New Jersey, it is clear that these types of disasters can and do happen.

If you have any questions about how to establish an emergency action plan, or how to properly distribute it and train your employees on it, please contact us. If you have anything you would like to add about emergency action plans, please leave a comment.

Lockout Tagout Training

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Creating and maintaining effective lockout tagout procedures is only the first half of the lockout tagout battle. After you have created your procedures and put a serious plan in place to monitor these procedures, you need to ensure your procedures are efficiently distributed to all required employees and that adequate training is in place. If this training and distribution is not done, then the procedures will not be properly followed and accidents will still be a real threat.

When dealing with training for lockout tagout, it is first important to be certain that your procedures meet all requirements. To do that, you can review OSHA Standard 1910.38. If you have any questions about the technicalities of the procedures, you can also always contact a qualified safety consulting firm to have a third party audit performed on your procedures. After determining that you do, in fact, have appropriate procedures in place, you will also want to be sure your mechanism for maintenance is appropriate, as well. Now, you can do this in house, with a third party, by hand, or with a computer program. The choice is yours.

Once you have these foundational pieces in place, it might be a good idea to bring somebody on board to help with training, at least in the beginning. This can be an experience lockout tagout professional who you hire full time or a third party. Either way, it will make the training more useful and help you to know that your employees truly understand their role in lockout tagout safety.

If you have any questions about establishing lockout tagout procedures or establishing a lockout tagout training program, please contact us. If you have anything to add about the importance of lockout tagout training, please leave a comment.

What are OHSAS 18000 and ISO 14000?

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OHSAS 18000 is a series of standards a company can put in place to ensure workplace safety. ISO 14000 is a series of standards a company can put in place to limit the company’s impact on the environment. These two sets of standards have very different objectives, yet are very similar at their core.

Both OHSAS 18000 and ISO 14000 attempt to streamline all of your current processes and procedures into one coherent place. OHSAS 18000 creates an occupational health and safety management system. This is a system that ensures all procedures and policies meet OSHA’s requirements, that all procedures and policies are harmonious with one another, and that no contradictions or errors exist. This system takes any company to the next level of safety, and it does so by structuring the processes already in place and adding a few new ones.

ISO 14000 helps a company to be more environmentally friendly by examining how products are produced, rather than focusing on the end result. There are many regulations in place which monitor what a company produces, so ISO 14000 attempts to fix issues during production, where there might be hazier requirements.

Both the OHSAS 18000 and ISO 14000 certifications are awarded by third parties. And if your company is interested in attaining either of these designations, it is important to work with a qualified consulting firm that truly understands the intricacies of these programs. A good consultant will audit your existing processes, help you to put new processes in place to meet the rigorous certification guidelines, and help you to put a plan in place to monitor your compliance long term.

If you would like more information on either of these certification programs, or if you would like to get started in putting a plan in place to become certified, please contact us. If you have anything to add about OHSAS 18000 or ISO 14000, please leave a comment.

Lockout Tagout in the News

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We blog often about lockout tagout, and the need to ensure your lockout tagout procedures are properly implemented and properly monitored. If they are not, there is a real risk to employee safety and a real risk that the company will be cited by OSHA. Lockout tagout is governed by OSHA Standard 1910.147; if you have never reviewed this standard, please do so.

In 2011, a horrible accident at an Adams Thermal Systems plant in South Dakota left one man dead. Two years, and several hundred thousand dollars in lawyer fees, later, Adams Thermal Systems has agreed to pay $1.33 million in fines to OSHA and to make an additional $450,000 payment to the man’s widow. And the executives here got off light; they were facing potential criminal charges.

I know we sound like a broken record at times, but the truth is that workplace safety is one of the few things that are 100% in your control at work. You cannot control the price of raw materials or public demand, but you can ensure you have an adequate safety plan in place.

If you have not recently had your facility audited, it might be time to consider a third party safety audit. And if you are not confident in your lockout tagout procedures, please bring in a professional to help.

If you have any questions about any workplace safety issues at your company, please contact us. And if you have anything to add about the tragedy in South Dakota, please leave a comment.

Evacuation Plan

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An evacuation plan is nothing more than a document which shows where a staff member should go in the event of an emergency to most efficiently exit the building. It is no more than that. It might include shelters, zones, back up routes, or color coding, but at its core, any evacuation plan should focus on an employee’s ability to leave the facility. Now, you can add zones, shelters, back up routes, and color coding to an evacuation plan to make it easier for employees to leave the building in an emergency situation, and we would recommend that you do that, but do not let these additions detract from the point of the plan – helping employees to safely and quickly exit the building.

To help employers stay on track and create an efficient evacuation plan, OSHA created Standard 1910.36, which gives specific guidelines pertaining to the creation and dissemination of evacuation plans at work. And while there are a number of specific guidelines set for just about every circumstance imaginable, what is most important to remember is that every company needs to create an evacuation plan for every facility.

We have had clients with small facilities in the past who, when asked for their evacuation plan, laughed and said they did not have one because their facility was so small. Unfortunately, common sense is not an acceptable evacuation plan, even if you only have two rooms and one door to the outside. If you do not have a viable evacuation plan, or have not reviewed it recently, create a good plan which fits OSHA’s requirements.

If you have any questions about how to create an evacuation plan, where to post it in your facility, or how to handle a specific issue with your plan, please contact us. If you have anything to add about evacuation plans, leave a comment.

Arc Flash and Shock Analysis

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Arc flash is one of the most overlooked workplace hazards we encounter. It is not because employers intend to put their employees in harm’s way or because safety teams do not do a good job, it is because OSHA relies upon the NFPA to handle the regulations. This creates a situation where some people do not realize that the regulations are required, and where others think they can choose what to follow and what not to follow.

If arc flash, electrocution, or any other shock hazard are a concern at your place of business, please make sure you review NFPA 70E in its entirety. This is the official standard for arc flash and shock safety, and should be followed. There are many “quick guides” and “summaries” available when it comes to arc flash analysis, but while they may be easier to understand, they are not the regulations.

Arc flash and electrocution hazards are among the most dangerous workplace hazards. Errors in these areas can and will result in death, and can and will result in large fines. If you are not sure your procedures and signage are up to code, consider a third party audit. In the event of an emergency, your employees will thank you.

If you have any questions about arc flash and shock hazards, or about how a third party safety audit can help you prepare for these situations, please contact us. If you have anything to add about arc flash and shock hazards, please leave a comment.