Monthly Archives: March 2014

Changing Lockout Tagout Procedures

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Something we have been running into a lot lately is companies which need to change their lockout tagout procedures. These requests are coming in for a number of reasons – new facilities, new machinery, outdated procedures, new personnel, etc. – but the desired outcome is always the same: change the current lockout tagout procedures which are no longer accurate or up to date. And we are finding most of these companies come to us after they have already attempted to fix their broken procedures themselves, leaving us with some pretty complex issues to work out.

So if you find yourself in a situation where you need to change your lockout tagout procedures for any reason, it is not usually advisable to try it on your own if you are not an expert in the field. And the reason for this is simple: if creating lockout tagout procedures is hard, amending someone else’s existing procedures is nearly impossible.

Fortunately, there are a number of reputable companies around which specialize in lockout tagout procedure creation and maintenance. So instead of trying to be a jack of all trades, you can focus on your business and leave the lockout tagout nightmare to someone else. And if you hire a good lockout tagout firm, then you will have procedures which are designed to account for future changes.

If you have any questions about how to change your current lockout tagout procedures, please contact us. And if you have anything to add about changing lockout tagout procedures, please leave a comment.

OSHA Orders DISH Network to Pay Over $257,000 to Ex-Employee

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DISH Network recently was ordered to pay more than $257,000 to a former employee after they were found guilty of blacklisting the employee. These charges were broken down as $157,024 in back wages and $100,000 in compensatory damages. These terms were determined after an OSHA whistleblower investigation found that DISH Network blacklisted the employee as a retaliatory action. Thought unknown to most employers, anti-retaliation and whistleblower rights fall under the jurisdiction of OSHA.

“A worker has a right to report wrongdoing to their employer without fear of retaliation during their employment and after,” said Robert Kulick, OSHA’s regional administrator in New York. “Blacklisting is a particularly insidious form of retaliation that can follow workers and even cost them new jobs. It is not only an unacceptable practice, it’s illegal.”

DISH Network retaliated against this employee by refusing to work with a subsequent employer, giving a negative job reference, and refusing to carry a satellite channel the employee worked for. These actions are considered retaliation by OSHA, and are punishable with hefty fines.

To protect yourself from similar issues, it is important to always have accurate and up-to-date whistleblower signage available to employees. In addition, you need to ensure whistleblower and anti-retaliatory procedures are clearly defined within your Safety and Health Management System as well as your company policies.

If you do not have whistleblower and anti-retaliatory signage or policies, contact us and we will help you become OSHA compliant. If you have anything else to add about this finding or about anti-retaliatory procedures, please leave a comment.

OSHA Fines Schwan’s, Adecco Staffing, and Cimco $264,360 for Serious Violations

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The US Department of Labor’s Occupational Safety and Health Administration has cited Schwan’s Gloal Supply Chain, Inc. for 32 serious health and safety violations due to issues found at their Atlanta facility. During OSHA’s September investigation, inspectors also found 18 safety and health violations relating to temporary employees of Adecco USA, Inc. and maintenance workers of Cimco Refrigeration, Inc. Most of these violations related to employees handling and working with ammonia, and focused around inadequate training and personal protective equipment. The fines for these citations total $264,360.

“All workers, whether full-time or temporary, deserve the same commitment and access to a safe workplace. Schwan’s, Cimco Refrigeration and Adecco are not providing that for their employees,” said Bill Fulcher, director of OSHA’s Atlanta-East Area Office. “OSHA standards are there to protect workers from predictable and preventable injuries and deaths. These standards were disregarded at the expense of worker safety.”

As you can see in this example, OSHA held multiple companies liable for the same offenses. This is important to keep in mind if your company ever hires on temporary employees or if your employees ever work off site; in either situation, you could be liable for any OSHA violations. If you do have a situation like this, even if you simply hire on contract or seasonal employees, it is important to have a qualified third party safety and health organization review your safety standards to ensure your employees, and any temporary employees, are safe at your facility or another facility.

If you have any questions about how to ensure the safety of your employees or temporary employees who work at your facility, please contact us. And if you have anything to add about this OSHA investigation, please leave a comment.

Creating Efficient Lockout Tagout Procedures

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When thinking about creating lockout tagout procedures, efficiency is often not a consideration. Instead, most safety personnel and business owners focus on getting done as quickly as possible while staying within the complicated requirements of OSHA Standard 1910.147. But inefficient procedures can lead to long term complications which can create headaches for years down the line. So when creating your system, keep efficiency in mind.

By efficiency, we mean several things – how easy are the procedures to read, how easy are the procedures to update and amend, have redundancies been eliminated, and have unnecessary tasks or steps been removed. These four areas of your lockout tagout procedures, if not efficient, can create health and safety risks to employees should a lockout tagout event occur, can create a need to rewrite your entire procedures in the event of a change in the future, and can cost tens of thousands of dollars in wasted employee hours.

To reduce these inefficiencies, it is advisable to have a qualified third party lockout tagout specialist review your lockout tagout procedures. Someone with years of experience in the industry will easily spot inefficiencies and errors, streamlining your procedure and setting you up for success today and into the future. And with online tools like our Factory Solutions Software, you can sleep easy knowing that your procedures will remain up to date and efficient going forward.

If you have any questions about creating lockout tagout procedures or about lockout tagout procedure audits, please contact us. And if you have anything to add about creating efficient lockout tagout procedures, please leave a comment.

OSHA Proposes $560,000 in Fines for Custom Rubber Products

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OSHA initiated an investigation against Custom Rubber Products, LLC in September of 2013. At that time, OSHA was notified of an incident where a machine operator’s arms were crushed. On Thursday, OSHA released a report citing Custom Rubber Products for eight willful, egregious violations surrounding a lack of machine guarding. Theses violations come with proposed penalties totaling $560,000.

“In an instant, moving machine parts can crush workers or amputate fingers or limbs,” said Assistant Secretary of Labor for Occupational and Health Dr. David Michaels. “Safeguards are essential to protect workers from these preventable injuries. Employers must ensure that guards are functioning on machines that can cause these injuries, and there is no excuse for failing to provide them.”

The eight willful violations were cited for failing to provide one or more methods of machine guarding to protect the operator and other workers in the machine area from hazards created by rotating parts while operating seven manual lathes and other equipment. A proper inspection of plant safety could have prevented this horrible injury and saved this company from a very hefty OSHA inspection.

If you have machinery in your facility, it is important to ensure your machine guarding is properly in place and that all guarding is up to code and properly functioning. If you have not reviewed your machine guards recently, or have not recently reviewed your policies surrounding machine guards, it is advisable to contact a third party safety and health auditing firm to review  your facility and your procedures.

If you have any questions about machine guarding, please contact us. If you have anything to add about the recent fines for Custom Rubber Products or about the importance of machine guards, please leave a comment.

OSHA Proposes $81,450 in Fines for Pressed Paperboard Technologies LLC

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Pressed Paperboard Technologies, LLC has been cited by the US Department of Labor’s Occupational Safety and Health Administration for nine safety and health violations. These violations consist of two willful violations, five serious safety violations, and two serious health violations. OSHA has proposed $81,450 in fines as a result of these citations.

“Pressed Paperboard Technologies has a responsibility to protect workers from electrical hazards at work,” said Kim Nelson, OSHA’s area director in Toledo. “These hazards expose workers to the dangers of arc flash, electric shock and electrocution. Employers must train workers to work safely with electricity.”

The two willful violations resulted from a lack of adequate training for employees working on energized electrical equipment and a lack of adequate personal protective equipment.

The five serious safety violations include failing to develop machine-specific procedures to prevent accidental startup or movement of machine parts that can cause injury; not training workers in lockout/tagout procedures when conducting maintenance on machinery; failing to disconnect electrical panels from all energy sources prior to conducting maintenance work; inadequate machine guarding on milling machines; and failing to test electrical personal protective equipment every six months.

The two serious health violations involve exposing workers to explosion and fire hazards while working near an indoor dust collector that lacked a means of explosion protection, and failing to establish and implement a written respiratory protection program.

As you can see, these violations cross several fields from lockout/tagout to arc flash to respiratory protection. When OSHA comes to audit a facility, the auditor does not focus in only on the incident which prompted the audit. The auditor will do a full facility audit, and will find every safety violation in your facility. For this reason, it is important to implement routine third party safety audits to ensure there are no vulnerabilities in your safety and health management system.

If you have any questions relating to third party safety audits or your safety and health management system, please contact us so that we can help ensure your company is up to code with all things OSHA. And if you have anything to add about this OSHA investigation or about third party safety audits, please leave a comment.

Confined Space Program

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An average of almost 2 workers per week die from confined space accidents. Most of these fatalities occur as a result of oxygen deficiency or the inhalation of toxic substances. In 2013, these two accident types accounted for 91% of all confined space accidents. With a properly developed confined space program, every single one of those fatalities could have been avoided.

When developing a confined space program, you need to first review OSHA Standard 1910.146. Standard 1910.146 sets the minimum safety requirements for all things confined spaces. It defines what a confined space is, defines in what situations a permit entry system is required, what to do in the event a hazardous atmosphere is present in the confined space, and how to properly maintain the space.

With the definitions and directions from Standard 1910.146 in mind, it is time to create your confined space program. In order to do this, you will first need to assess your facility to determine how many confined spaces you have. From there, you need to assess the individual spaces and, based upon the requirements set in Standard 1910.146, determine if a permit entry system is required, or if there are any special circumstances surrounding your spaces.

From there, you need to create procedures which take into account personal protective equipment, signage, a permit entry system (if applicable), a toxic substance plan (if applicable), and what your rescue plan is in the event of an emergency. Finally, you want to ensure your plan is able to adapt to future changes, meaning that you have someone monitoring Standard 1910.146 in case of updates and that you have provisions for how to add additional regulations should additional confined spaces or changes to your current confined spaces need to be accounted for.

If you have any questions about creating or updating a confined space program, please contact us. If you have anything to add about how to create a confined space program, please leave a message.