Monthly Archives: December 2013

OSHA Fines Olé Mexican Foods $150,000 for Repeat Violations

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 IN 2011, Olé Mexican Foods was cited for, among other things, failing to ensure workers performing equipment servicing and maintenance understood the energy control program and procedures and for caught-in and amputation hazards from the points of operation on equipment in the production area. Earlier this year, OSHA revisited Olé Mexican Foods. Today, they announced over $150,000 in citations, many of which are repeat violations from 2011.

According to William Fulcher, director of OSHA’s Atlanta-East Area Office, “This employer received citations for the same hazards earlier and did not correct them. Additionally, amputation and caught-in hazards remained, posing a risk of serious injury or even death for their workers. These hazards must be eliminated immediately from the workplace.”

The penalties for the repeat violations totaled $77,000. In addition, there were $73,030 in penalties for new serious safety and health violations. These violations included failing to clearly and specifically outline the energy control procedures for all energy sources on the mixers and production equipment; instruct each affected worker on the purpose and scope of the energy control program; ensure authorized workers in the energy control program were utilizing lockout procedures when performing service on mixers; cover drainage troughs and guarded platforms to prevent trip and fall hazards; prevent exposure to amputation and caught-in hazards from protruding shaft ends and unguarded chain and sprockets; and ensure unobstructed exit routes. Other violations include failing to ensure workers spraying corrosive chemicals use splash goggles; provide an emergency eyewash station; provide appropriate hand protection; and conduct audiograms for temporary workers exposed to noise levels in excess of permissible exposure limits.

And while this seems like a laundry list of issues you would not expect to find in a normal factory, it is amazing how easily many of these issues can be overlooked. So if you have recently been audited by OSHA, or if you have not recently had a third party safety audit, it might be a good time to contact a qualified third party safety auditing firm to review your workplace.

If you have any questions about third party safety audits, or OSHA regulations in general, please contact us. And if you have anything to add about the Olé Mexican Foods fines, please leave a comment.

Lockout Tagout Auditing

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Whether your lockout tagout procedures have been established for only a few months or for several years, it is important to routinely audit your lockout tagout procedures. This ensures that any changes or updates which have been made were done properly and that any changes or updates which should have been made, either due to changing equipment or changing regulations, are made. Audits protect employees from unnecessary risks and protect management from fines.

A proper lockout tagout audit should, at a minimum, include a full audit of each machine, each placard, and piece of signage. This information should be compared to current OSHA and Corporate requirements, and all of the information found should be properly recorded.

Once the audit is complete, this information should be compiled and included in a final report, which explains the findings and requirements to fix these errors. Among the things covered in the report, there should be a facility equipment list, with a breakdown of the number of energy sources per piece of equipment, the equipment missing lockout procedures, the equipment with compliant lockout procedures, the equipment with non-compliant lockout procedures, and an equipment specific list of all compliance deficiencies.

With that information, your auditor should create a plan to fix any deficiencies and bring your facility up to code. Your auditor should also go over ways to ensure compliance going forward, including methods to monitor your lockout tagout procedures.

If you have any questions about a lockout tagout audit, or about ongoing lockout tagout monitoring, please contact us. If you would like to add anything about the importance of regular lockout tagout auditing, please leave a comment.

OSHA Proposes Changes to the Process Safety Management Standard

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In response to Executive Order 13650, which requires OSHA and other federal agencies to improve the safety and security of chemical agents, OSHA has proposed several major changes to the process safety management standard. These proposed changes are currently in a public comment stage, which means the public has 90 days to register a comment. So if your company is in an industry which will be affected by the changes, it is imperative that you keep track of how these changes will impact your company.

The proposed changes include eliminating the process safety management standard exemption for atmospheric storage tanks and oil and gas-well drilling and servicing. The changes would also reinstitute enforcement of oil and gas production facilities and expand coverage for reactive hazards. The changes would add additional chemicals to the list of highly hazardous chemicals and revise and reevaluate equipment and some processes currently required for process safety management.

There are also a number of rules changes surrounding clarification of current rules and terms on file. OSHA plans to define “recognized and generally accepted good engineering practices,” to make clear Paragraph (I) of the process safety management standard, and to update the audit requirements of part (o) of the Process Safety Management standard.

These are just a few of the proposals recently made by OSHA. Employers are currently being asked for comments on the proposed changes, so if you plan to comment, do so before the comment period ends.

If you have any questions on these proposed changes and how they might impact your business, please contact us or leave a comment.

Fire Protection Planning

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Any firefighter will tell you that the best way to fight a fire is to stop it from ever getting started. And while this advice seems obvious, it always surprises us how many companies we audit which do not have adequate fire prevention and protection procedures. And since we consider adequate to simply mean following the basic requirements of OSHA Standard 1910.155, that means that these companies are not only putting their employees at risk, they are in violation of an important OSHA standard.

This standard regulates fire protection and prevention equipment and processes. It sets minimum guidelines for what equipment is required to be present in a facility. It further sets guidelines on how often this equipment must be tested, how it must be stored and maintained, and how it must be labeled. The type of equipment covered in this standard is very basic fire prevention equipment. This is equipment such as fire extinguishers, fire alarms, employee alarms, sprinkler systems, and smoke detectors. A majority of fires can be prevented or suppressed with this basic equipment.

If your facility is lacking any of these items, or if they are not regularly tested and maintained, then it might be time to review your fire protection procedures. And if you want to bring your facility’s fire protection planning up to a higher standard, please contact a qualified third party safety auditing firm to guide you in that; it is one of the best things you can do for your employees.

If you have any questions about standard 1910.155 or about fire protection in general, please contact us. If you have anything to add about the importance of fire protection planning, please leave a comment.

Lockout Tagout (LOTO) Procedure Monitoring

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OSHA Standard 1910.147 sets very specific guidelines surrounding “the control of hazardous energy” (or lockout tagout). However, these guidelines can be extremely difficult to comply with, initially, and can be even more difficult to maintain. This is due to the ambiguous nature of parts of the standard and the variability of the lockout tagout procedures.

In order to prevent errors, most companies hire third party lockout tagout specialists to assist in creating and monitoring their lockout tagout procedures. Here at PF Safety, we take lockout tagout very seriously, and have found the best way for us to help our clients with the many potential pitfalls with lockout tagout is with web based software specifically designed to create, track, and monitor lockout tagout procedures.

This software is fully customizable, fully scalable, and can be accessed anywhere an internet connection is available. It is available to all of our clients, and is far more cost effective than other options which require a dedicated lockout tagout person. This software also allows you to stay engaged in your lockout tagout monitoring, and will help you to learn the ins and outs of your lockout tagout procedures. By leaning about your procedure and having a somewhat engaged approach to your lockout tagout procedures, you will be better prepared should your facility ever be audited.

If you have any questions about our Factory Solutions Software, or about lockout tagout in general, please contact us. And if you have anything to add about Factory solutions Software, or about lockout tagout procedure monitoring, please leave a comment.

OSHA Signs and Safety Signs

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At any place of business, it can be expected that safety signs will be posted in plain sight warning both employees and the general public of potential hazards of all kinds. These signs are strategically placed to allow anyone who is present to see the sign from a number of different angles. These signs must meet very strict guidelines set by OSHA to ensure that no matter who is reading the sign, that person will have an idea of what hazards are around them.

OSHA regulates safety signs with Standard 1910.145. This standard creates a uniform experience for all, allowing anyone to go into any facility and understand the present hazards. But in order for OSHA to create such a system, they set very stringent guidelines on what signs must look like, how they must be presented, in what situations different signs must be used, and what size and color various signs must be.

For this reason, it is important to have your signs reviewed at least annually, to ensure no changes have been made to the safety signage guidelines. It is also important that your safety signs are replaced as they age, as small details such as borders or chipping numbers can create an issue down the line.

If you would like to review some OSHA friendly signage, please review our store. And if you have any questions about safety signs, please feel free to contact us. If you have anything to add about safety signs, please leave a comment.

Establishing an Evacuation Plan

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In the event of an emergency, it is important to have a plan in place which allows your employees to safely exit the facility. This plan should also include elements which allow for multiple escape routes, if the building has multiple entrances, in the event one is blocked. Further, there should be a set procedure for ensuring the employees are all out of the building and safe. And finally, you want to be sure you have an effective business continuity strategy to keep your business up and running, even in times of emergency.

When establishing your evacuation plan, you need to ensure you are compliant with OSHA Standard 1910.36 and Standard 1910.37. These standards set guidelines on how to create specific evacuation routes, how to maintain the routes, and what features are required in the routes and the exits. These standards are also of extreme importance when building a new facility, as they explain what is required of the construction of evacuation routes and exits.

If you have a plan in place and are worried it does not conform to these standards, or if you need to establish a new evacuation plan, it might make sense to consider a third party safety audit. A good third party safety auditor will ensure your plan fully adheres to OSHA Standards 1910.36 and 1910.37, and that your plan will keep your business running smoothly through an emergency situation.

If you would like more information about establishing an evacuation plan, please contact us. And if you have anything to add, please leave a comment.