Welding, Cutting, and Brazing (29CFR1910.252)

There are a lot of industries which require at least occasional welding, cutting, or brazing. And for these industries, OSHA ensures safety is maintained through Standard 1910.252. This standard is an overview of all safety requirements surrounding these dangerous procedures, however by following these guidelines, welding, cutting, and brazing can be effectively performed without risk to your employees.

The first, and most serious, guideline listed surrounds fire prevention and protection. OSHA prefaces the discussion of fire prevention practices by citing NFPA Standard 51B,1962, which is the basis for this OSHA standard. It then goes on to state that all fire hazards must be removed from the vicinity, guards must be used if these items can not be removed, and that there are a number of special precautions which must be followed in various unique circumstances. It is also important to seal openings in the floor below work zones, ensure sprinkler systems are functioning properly, and have adequate fire extinguishing materials present. Finally, you need to employ fire watchers in a number of situations where a fire or the spread of flames may be more likely.

OSHA also looks at the individual performing the welding, cutting, or brazing. OSHA sets forth a series of requirements surrounding personal protective equipment, focusing on various types of equipment in different situations. This is everything from eyewear to self ventilators, with a large number of specific regulations specifying which eye protection is required, down to the specific lenses and hand shields.

Finally, OSHA requires that adequate ventilation is available. Whether this is through self contained ventilators or ventilation systems, your safety team needs to have a ventilation plan in place. If you do not have a compliant ventilation plan in place, it might be time to consider hiring a professional firm to help you develop your plan.

If you need any help in deciphering Standard 1910.252, or if you have any other specific questions, please contact us. And if you have any pointers for staying within OSHA’s guidelines without impairing your daily welding, cutting, or brazing operations, please leave a comment.

Walkways (29CFR1910.22)

There are a number of standards set forth by OSHA which cover the “walking-working surfaces” of a place of employment. Previously, we covered the general requirements of Walking Working Surfaces and the specific requirements surrounding Guarding Floor and Wall Openings. Additionally, OSHA created Standard 1910.22 which discusses general housekeeping and maintenance for floors, specifically areas considered aisles or passageways.

The primary objective of this standard is to ensure the floors your employees walk across are clean and unobstructed, and that no surfaces are over encumbered by items heavier than they are approved to handle. The first piece to this surrounds keeping areas orderly and sanitary. So, don’t leave obstructions all over the floor to trip your employees, and if you work with hazardous materials, don’t leave them a mess on the floor. Also, keep your floors clean, allow for drainage if necessary, and properly sign areas that are slippery.

Next, you need to make sure you mark all aisles and passageways, provide guardrails if there is a hazard nearby, and allow safe clearance should mechanical handling equipment be used in close proximity. Once you have met these criteria, you need to ensure you maintain these areas and keep them in good repair with no obstructions.

Finally, you need to ensure you have proper marking plates in place denoting the allowable loads for various surfaces throughout your building. These limitations are to be determined by a building official and need to be maintained. It is also important to follow these weight guidelines, because it can be a serious hazard should a support give out from excessive weight.

By following these steps, you will have a safer workplace that is OSHA compliant. If you are having trouble finding ways to bring your facility up to code, or if you have any specific questions about this standard, please contact us so we can help. And if you would like to add anything on this subject, please leave a comment.

Stairways (29CFR1926.1052)

Most facilities utilize stairways in one way or another for daily or occasional business purposes. This can be stairs between floors, stairs to a storage basement or storage attic, or stairs out of the back loading dock of a warehouse. Regardless of why there are stairs, or how often they are used, if there are stairs in your facility, then they must be up to code as per OSHA Standard 1926.1052.

Whether your staircase is temporary or permanent, under construction or in use, this standard must be consulted before any changes are made, and at least annually during audits to ensure stairways remain safe for employees and customers. This standard regulates the size of steps, the height of steps, the dimensions of landings, the angle of the stairway, the material used to create the stairways, doors and gates on a stairway, the condition of the stairway, stairways under construction, stair-rails, and handrails. Stairways must be kept clear of clutter and debris, as well as “hazardous projections, such as nails.” There must be adequate treads, and all steps and landings must be filled with concrete or at least covered by a hard, solid, wooden plank. All materials used in stair construction must be solid, firm materials, and must ensure safety. All steps must be of uniform height, width, and depth. And don’t forget to hang proper signage as applicable.

If, after reading this brief synopsis, you have any questions about the stairways in your facility, or about any remodeling projects you are planning which involve stairways, please contact us to get more information on this important OSHA standard. And if you have anything to add about this topic, please leave a comment.

Portable Tools and Equipment (29CFR1910.241)

As we discussed a few weeks ago, hand tools and equipment are used in nearly every field. And while 1910.242 discusses the safe use of these tools, it does not define what these tools actually are. So to avoid confusion, OSHA also created Standard 1910.241, which clarifies and defines what is, and is not, a hand and portable powered tool or other hand-held equipment as well as what the potential safety risks are with certain types of tools. Understanding these definitions can help any business owner determine how to properly regulate their tools and machinery.

This standard discusses and defines explosive-actuated fastening tools, abrasive wheels, and jacks, as well as all of the potential hazards and safety precautions which can be taken. For some tools, the classification is quite obvious, but for others it may not be clear if these standards are applicable. To help you determine if your tools are governed by these standards, you can either refer back to the standards, and attempt to determine if your tools fit their classifications without qualifying for an exemption to a different class, or you can contact a professional, who can help you classify each of your tools. Either way you decide to classify your equipment, it is also important to remember to include these tools in your annual third party safety audits.

If you have any questions about this standard, or how to properly classify your portable and hand powered tools and equipment, please contact us so that we can help you to better understand these definitions and what you need to do with each different class of tool. If you have anything to add about hand and portable powered tools, please leave a comment.

Annual Safety Audits

Many business owners do not understand why they need annual safety audits, and while not necessarily a requirement by OSHA for every business in every industry, most every business is regulated by a standard which has an annual third party safety audit component. Further, as per Docket No. W-100, voluntary third party safety audits can help prevent citations and fines if violations are found but are being corrected after discovery during a recent audit. Finally, the only way to ensure your business is not in violation of any OSHA standards is to have a professional firm with experience in OSHA regulations review your Safety and Health Management System, as well as your work cite.

When done properly, third party safety audits review every aspect of your business operations. Auditors will review the Safety and Health Management System to ensure your current processes are up to code and to see what additional processes need to be inserted. Based upon your industry, auditors will then compare your daily business practices with OSHA’s requirements, to ensure your employees are following all safety protocol. Auditors will also review training procedures for new hires and annual training for staff members. Finally, the team will do a wall to wall inspection of your facility, as a way to ensure there are no additional hazards which need correcting.

After this process is complete, a good auditor will give you the results of your audit, including where there are deficiencies, and work with you to develop a plan going forward of how you will correct your problems. If these are not the services you are receiving from your current auditing firm, or if you would like to learn more about the benefits of annual third party safety audits, then please contact us. And if you would like to add anything about the benefits of annual safety audits, please leave a comment.

Handling Materials (29 CFR 1910.176)

If you work in an industry which requires the use of mechanical handling equipment, then OSHA Standard 1910.176 is surely a concern for you. Or, at least, it should be. This standard was established by OSHA to govern the proper use of mechanical handling equipment, the storage of materials, and the maintenance of the storage locations. It sets very broad requirements and expects you, as the business owner, to ensure you are in compliance.

First, “Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repair, with no obstruction across or in aisles that could create a hazard. Permanent aisles and passageways shall be appropriately marked.” (1910.176[a]) As you can see from this, ensuring aisles and passageways are clear is an important part of this standard. No equipment or mechanical handling equipment may block aisles and passageways, and permanent aisles and passageways need to be kept clear and properly marked with adequate signage. If you are unsure of what constitutes “adequate,” you might consider hiring a third party to audit your facility, to ensure you are in compliance.

It is also important to remember that the storage and maintenance of materials must not cause a hazard. This means that items stacked upon each other must be properly secured. The location where the materials are held must be kept cure of accumulating materials which can create hazards from tripping, fire, explosion, or pest harborage. Finally, proper signage must be used to mark clearance limits as applicable.

If any of this seems like a potential concern for you and your business, please contact us so we can you ensure you are compliant. And if you have anything to add about Standard 1910.176, please leave a comment.

Medical Services and First Aid (29CFR1910.151)

In the event of an emergency or workplace accident, it is important that employees have quick access to the necessary tools and personnel to help with the problem. For many workplace injuries, quick attention from a knowledgeable professional can be the difference between a minor injury and a serious one. Because of this, OSHA created Standard 1910.151 which governs access to medical personnel for advice and consultation on matters of job site health.

For larger organizations, the expectation is an onsite infirmary or onsite specialists available to help with emergencies and workplace questions. In lieu of that, a nearby infirmary, clinic, or hospital is required. These steps will ensure that adequate and speedy care can be taken to help an injured associate. If none of these other options are available, then it is up to the owner to train a person or persons how to administer first aid. Further, the company is required to carry first aid supplies. It is also the responsibility of the employer to offer eye and body flushes to employees who handle injurious corrosive materials.

The easiest way to ensure you are up to code with Standard 1910.151 is through a third party safety audit or a direct consultation with a qualified third party. Remember, this standard is not only important because failure to comply might result in fines; failure to comply means that an onsite injury will not be properly managed and serious injuries can result.

If you have any questions on Standard 1910.151 or third party safety audits, please contact us. And if you have anything to add about medical service and first aid requirements, please leave a comment.

Walking and working surfaces

In 2011, The U.S. Bureau of Labor Statistics reported that 7.5% of all recordable injuries and illnesses and 14.4 % of all fatal injuries in the private industries involved slips, trips and falls. These statistics are second only to motor vehicles as a cause of fatalities. The National Safety Council’s Injury Facts 2009 edition estimated the average cost of lost time injury was about $43,000 per incident. Slips trips and falls cost the U.S. economy 10’s of billions of dollars annually.

The general duty clause of the Occupational Health and Safety Act mandates that “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards…” OSHA established 1910.21-27 standards to address the safety concerns of walking and working surfaces in the workplace. In compliance with these standards, employers are expected to keep all places of employment, floors, passageways, stairways, and storerooms clean, orderly, in sanitary condition and free from any health and safety hazard.

Floors should be kept clean and dry as far as possible. Employers are required to maintain drainage, platforms, mats or other dray standing places where wet processes are used. Every workplace floor and passageway should be free from protruding nails, splinters, holes, or loose boards to facilitate cleaning.

Aisles and passageways should have sufficient safe clearances for mechanical equipment and should be marked appropriately. Covers and guardrails should be provided where necessary to protect from the hazards of open pits, tanks, ditches, etc. Loads should never exceed the approved structural load of the building floor. Maximum load should be marked and affixed in the appropriate areas.

Every stairway with four or more risers, floor openings measuring 12 inches or more in their least dimension, ladder-ways, skylight or manhole floor openings, all should be guarded by standard railing. Winding stairs should be equipped with handrail offset to prevent walking on all portions of the treads having width less than 6 inches.

All ladders are required to be free from damage and rungs free from grease and oil. The foot of the ladder should be positioned no more than one-quarter of their working length from the top to prevent slippage. Ladders should not be placed on boxes, barrels, or in places where it could block doorways. Ladders should be used only for their intended purpose not as platforms, runways, or scaffolds.

There is no silver bullet solution to slips trips and falls. It takes a proactive management to clean the clutter, create a safety culture, and train and make employees aware and part of the safety program.

Employees should avoid wearing loose shirts and dragging pants. Employees are expected to wear appropriate footwear and be trained to report any unsafe condition such as: uneven surface, worn tiles, loose mats or rugs, hose or chords in the walkways, cracks, holes, missing hole covers, missing guardrail, spilled coffee, oil leak, etc. Employees should be part of the hazard control process.

Many tripping hazards are housekeeping items. Hoses and chords across walkways are continual hazard. Rerouting or using protectors reduce these hazards dramatically. Cleaning spills and leaks right after they occur or reporting unsafe conditions as soon as they are observed should become the practice and concern of every employee.

A workplace safety program should include pre-shift inspections of all work areas to ensure no slip trip and fall hazards exist. Waste containers and spill cleanup materials should be easily accessible. Work areas should be well lit and any burnt lights should be replaced without any delay.

Comply with OSHA for a safer workplace.

Monitoring Lockout Tagout

The monitoring and maintenance of Lockout Tagout procedures is a tough task to ask of your safety team. It requires the team to create, track, monitor, and update the necessary procedures for Lockout Tagout. If any equipment changes, the changes need to be reflected in the procedures. If any staff rollover, the team must ensure that that staff member did not have critical information which is not kept anywhere else.

This task can become a full time job for a team which is probably already maxed out with other day to day safety needs. Luckily, there is now fully customizable software which can track and monitor your Lockout Tagout procedures. This software can be updated as needed to keep up with your company’s changing equipment needs, is fully scalable, and ensures you are up to code with your Lockout Tagout monitoring.

This software can be incorporated into your Safety and Health Management System and become a key component of your annual third party safety audits. By utilizing third party software to monitor and track your Lockout Tagout procedures, you are taking the onus off of your safety team and placing it upon someone else, lessening the burden you place upon this team.

If third party Lockout Tagout monitoring sounds like something that can help you to more effectively run your business, please contact us so that we can help you to better understand our product. And if you have anything to add about Lockout Tagout monitoring software, please leave a comment.

Identification of Piping (ANSI/ASME A13.1)

For many industries, piping which carries hazardous materials throughout a facility are a necessary evil. To help employees identify the materials flowing through these pipes, the piping must be properly labeled. This will both make employees aware of the materials flowing around them and, in the event of a leak or other problem, help employees or emergency personnel quickly identify what potential hazard exists. To make this labeling process simpler, ANSI/ASME A13.1 was created. This program creates a universal practice for labeling piping, including a color coded system which allows employees to identify the materials in pipes, even if they can not read the labels.

The color coded system has 10 unique color schemes, identified by the background color and the color of the writing. The system was updated in 2007, however some companies are still using the pre-2007 system. For those companies which are, it might be time to update, as your facility can lead newer employees to misrepresent hazardous materials if they report the labels to a third party in the event of an emergency. The quickest way to do this would be to bring in a professional organization who focuses on workplace safety.

ANSI/ASME A13.1 also covers the requirements of what is on the labels and how big the lettering needs to be. The labels should be short and concise, and have an arrow pointing in the direction of the flow. The lettering should be at least 1/2 inch high, and needs to increase in size based upon the diameter of the pipe.

If you are unsure if your facility has updated its piping labels, or if you would like more information on the exact requirements for your facility, please contact us so that we can assist you in creating a safe work environment for your employees. If you have anything else to add about the identification of piping as determined by ANSI/ASME A13.1, please leave a comment.