Safety Audits

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If you have been following our blog, you have seen that we talk about safety audits in just about every post. While it might seem redundant, it is really just that important for your company. There is nothing that can protect you from OSHA more than a safety audit administered by a qualified third party.

A good third party safety audit will cover everything OSHA looks for in an audit. We cannot speak for other companies, but we can say that during our audits we examine your current hazard assessments, machinery, processes, signage, training, employee safety competence, evacuation plans, accident incidents and investigations, and anything else that you need to ensure compliance with OSHA. This all encompassing view allows us to truly understand your company, your needs, and how to effectively minimize risk while not disturbing your company’s operations.

When shopping for a consulting firm to handle your safety audit, there are a few key factors to keep in mind. First and foremost, why is this organization qualified to audit your business? Do they have a team of engineers, auditors, safety professionals, and trainers who have very specific and very relevant knowledge of your industry? Or, did a recent college graduate read through some OSHA regulations and decide that he can handle understanding the intricacies of OSHA as it relates to your operations? You will also want to consider what other clients the organization has. We list a small sampling of some of our clients, to give you a feel of what industries we cover. If you start speaking to an audit team and they hedge when asked about which industries they specialize in, or what clients they have worked with, you might want to reconsider. Finally, you want to consider what the audit team will do for you after the audit process is complete. Will they help you stay in compliance over time? Will they forget about you in a month, and be unavailable to you if you have questions? Are they even going to write out a full plan of next steps?

If you have been considering a safety audit, stop procrastinating. It is never going to be a fun or desirable prospect, but it is a necessity. If you have questions about our process, or how we can help your company, please contact us. And if you have any other things you would recommend looking for in a third party audit team, please leave a comment.

Ventilation (29CFR1910.94)

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If your business uses abrasive blasting, you must have at least reviewed OSHA Standard 1910.94. This standard covers the ventilation requirements for any business which uses any form of abrasive blasting, including the minimum clean air levels, necessary personal protective equipment, minimum exhaust obligations, and required air purification methods.

It is common knowledge that silica sand, while extremely cost effective, is potentially lethal without a proper ventilation plan. What is less commonly known is what the effects are of other abrasives. For instance, what is required if you utilize garnet, instead of silica? What if you change from synthetic abrasives to another form, such as agricultural? What are the different requirements between wet and dry abrasive blasting? We have seen many companies who were in perfect compliance change their abrasive material and create a hazardous work environment. Likewise, a change could make an extremely hazardous work site into a perfectly safe environment, which would allow you to save a small fortune in now unnecessary ventilation costs.

Another important thing to consider is how you are purifying the air. Will you be utilizing personal protective equipment? Do you need a dust collector or exhaust system? Each blasting device being used with each abrasive material, creates a different potential hazard, and has different safety requirements. Further, these requirements are not static – as new information is discovered, new requirements are released by OSHA.

If you have not recently reviewed this standard or had a qualified third party review your ventilation methods, it might be time to hire a professional team to review your processes. If you would like any additional information, please contact us. If you have anything to add to the discussion, please leave a comment.

Lockout Tagout Monitoring

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We have previously discussed OSHA lockout procedure requirements, as per OSHA 1910.147. In this post, we would like to discuss maintaining your OSHA compliance after initially getting yourself compliant. It is difficult – extremely difficult – to maintain your compliance without the help of either a dedicated representative (or, in some cases, dedicated team) or software designed to monitor your compliance.

Luckily, many companies have developed user friendly software which can handle this task. With this software, you can create a baseline representation of your company and update it as machinery, personnel, and responsibilities change. This allows you to keep a current and fully updated framework, with annotations that document the changes your company has made. Further, this software will often allow specific individuals to log in and have access in real time to the stored information.

This software is a great tool to monitor your compliance in between annual audits, and should be used in conjunction with annual audits, and only after completing a facility wide lockout program. Once you set your lockout program, schedule your annual audits, and begin using relevant software, you will be guarding yourself against unexpected or unforeseen safety risks.

If you are ready to get some more information about the cost saving, time saving, and headache saving software that we offer, take a look here to get more information. Then, contact us to get started. If you have any additional information pertaining to lockout tagout monitoring, please leave a comment, so we can get a discussion on this topic going.

Spray Finishing (29CFR1910.107)

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If you use products that are coated with aerated solid powders, then you need to be sure you are in compliance with OSHA Standard 1910.107, which governs spray finishing using flammable and combustible materials. This standard discusses the spraying area, including the spray booth utilized, the venting, the parts uses, access doors, maintenance, cleaning, and signage, among other things. OSHA very clearly states exactly what is and is not acceptable leaving very little gray area for you to work with.

A spray booth requires a system for minimizing dust or residues entering exhaust ducts and permitting the recovery of overspray finishing materials. This can be most easily accomplished with a water washing system. In lieu of a water washing system, you must have either: distribution of baffle plates to promote an even flow of air through the booth or cause the deposit of overspray before it enters the exhaust duct, overspray dry filters to minimize dusts, overspray dry filters to minimize dusts or residues entering exhaust ducts, overspray dry filter rolls designed to minimize dusts or residues entering exhaust ducts, or, where dry powders are being sprayed, powder collection systems so arranged in the exhaust to capture oversprayed materials. Further, the ventilation system you use must meet similarly regulated specifications, including all requirements of NFPA 91-1961 and OSHA 1926.57.

The most common issue with this Standard, however, relates to proper signage. Required signs include: no smoking signs, safe distance signs, and other applicable warning signs, based upon your spray finishing operation. If you have not recently, it is a good idea to ensure that you have adequate signage, and that signs you have placed have not been inadvertently removed.

This has been a very high level overview of the Spray Finishing requirements set forth by OSHA. If you have not recently audited your operation, or have any questions about whether or not you are in compliance, please contact us and we can answer your questions or schedule an audit. If you have anything to add to the conversation, please leave a comment.

Hearing Conservation (29CFR1910.95)

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Understanding OSHA’s policy on occupational noise exposure and hearing conservation is essential to anyone who wants to run their business safely. Standard 1910.95 lays out exactly what OSHA expects of an employer in relation to testing, monitoring, employee notification, observation, evaluation, auditing, and required controls. Following this standard will ensure that you have created a safe work environment for your employees, and that you have an OSHA friendly work environment, in case you are ever audited.

OSHA created a very useful table (1910.95 (a) figure G-9) which can be used to determine if your work zone has any areas which require your attention. If you do have any high noise areas, you must take immediate action to either reduce the noise exposure, limit the length of exposure through various controls, or require proper personal protective equipment be worn at all times. Failure to act in this manner can lead to significant hearing problems for your staff and hefty penalties for you.

But your responsibility as the employer does not end there. OSHA requires that you properly monitor any high noise areas, regularly checking to make sure that your safety measures are adequately protecting your employees from harm, and that all affected employees are enrolled in your hearing conservation program. You must also routinely test your monitoring equipment to make sure it is acting effectively. Additionally, you must offer audiometric testing to all employees who work in the affected areas, to ensure that the methods in place are properly protecting your employees. They are required to be tested at least annually, and any significant threshold shifts must be reported and followed up on, to ensure employee safety.

If you have not had your company properly evaluated recently, it might be a good idea to consider bringing in professionals to ensure that your work space is up to code, and that your employees are safe from excessive noise exposure. Also make sure you properly sign any high noise areas, to both notify employees who are not usually working in this area, and to remind employees who do, to wear their protective equipment. Please leave a comment or contact us if you have any questions about this standard.

Machine Guarding (29CFR1910.212)

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OSHA standard 1910.212 discusses machinery and machine guarding. In this standard, OSHA lays out the requirement for the guards which must be in place to protect employees from potential harm due to unsafe machinery. OSHA lays out how to affix said guards to the machine, and how to act if a guard can not be affixed to the machine directly. Finally, OSHA lists specific types of machines which are likely to need guarding, and examples of how to guard several of them.

“One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks.” (1910.212 (a)(1)) This is OSHA specifically laying out exactly what kinds of dangers must be guarded against, and where they must be protected. So, if your company uses any machines like these, it is imperative that you properly guard them.

“Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible.” (1910.212(a)(2)) This is OSHA being very specific about how to implement your machine guards. If there is any conceivable way to attach the guards directly to the machine, then do it. And if you are unsure, then have a professional take a look, to make sure that you are in compliance.

OSHA then goes on to specifically list several machine risks and what, specifically, needs to be done to ensure their safety. If you have not recently had a third party safety audit, it might be time to consider one. An auditor will be able to see if you are up to code on your guards. You will also need to have proper signage around dangerous machines. If you have not already implemented your signage, check out our extensive collection of signs, to find one that fits your needs. If you have any questions about your machine guards, please contact us or leave a comment.

OHSAS 18000 and ISO 14000

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These standards concern the mechanisms in place to ensure the safety of employees working in a factory and to minimize the environmental affect of said factory. The certification process involves rigorous assessments and perpetual reviews, as well as extensive documentation of the processes you have in place to ensure safety and effective environmental awareness.

The processes necessary to meet these certification requirements are strikingly similar. At their core, these standards are practically indistinguishable; they both require similar documentation and processes. Because of this, one well designed product can help you to meet your regulatory requirements for both standards.

Unfortunately, this product would also have to account for the differences. Some of the major differences between these standards include: employee engagement, the risk reduction hierarchy of 18001, the differing intents, and the implementation of the processes. Without accounting for these differences, a company can not qualify for either of these important certifications.

This is where our Factory Solutions Software is effective. We designed this software to be an all encompassing program to keep your factory compliant in a number of different ways, including a number of key OSHA regulations and OHSAS 18001 and ISO 14000. With our software, you can set your processes, track your changes and evaluations, and ensure employee participation. Our software is all browser based, and can be incorporated with our other services.

We at PFSafety take safety seriously, if you should have any questions about these or any other standards, please contact us. And if you have anything else to add to our brief discussion of these standards, please leave a comment.

HAZWOPER (29CFR1910.120)

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Hazardous waste operations and emergency response (HAZWOPER, for short) guidelines are covered by OSHA standard 1910.120. This standard explains required training for employees dealing with hazardous materials, as well as procedures for the storage, disposal, and operations of all hazard materials and potential accidents with said materials. It explains who may and may not be granted access to such materials, and who is in charge of monitoring the site. Finally, it explains what is required in your business site safety and health plan.

1910.20 gives specific details about what is required in the site safety and health plan. It must include the specifics related to which hazards have been identified, how they were identified, and how these hazards were communicated to the individuals working on site. It also requires that all hazardous sites have an emergency response plan, including applicable state and local authorities where applicable. In addition, specific guidelines are set for monitoring the health of individuals who have been granted access to the site, as well as guidelines for the frequency of medical examinations. Further, the standard goes into detail about what is required of employee trainers, and how often employees must be trained. The standard also covers what personal protective equipment is to be worn. It covers what drums and barrels will be used to store and dispose of the materials, as well as how said containers are to be opened and sealed. The standard additionally discusses at length the proper disposal process for hazardous materials. This is of course, an abridged, and hardly all inclusive, list of what is required; but it does touch on the key points and shows how far reaching this site safety and health plan really is.

Even if you have had a full audit from a third party in the past, and created an in-depth site safety and health plan, it is important to make sure you are keeping adequate records of events and changes. Further, you must ensure that you are still up to code and that no additional risks have presented themselves in the interim. If you have any questions about your current plan, or would like to begin a new plan, please contact us for more information. And if you have any additional information to add, please leave a comment.

Third Party Safety Audits

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Properly managed Third Party Safety Audits can be the difference between a smooth OSHA visit and a disaster. During a safety audit, a certified audit team will provide an independent review of your operations, create a list of best practice recommendations, and form an Action Plan for your company to reach full compliance. In addition, any audits performed by a certified company will comply with all relevant federal and state health inspection requirements.

A third party safety audit is great for customers with a number of different needs. A third party safety audit can help you to: develop an elite safety program, obtain VPP Star/Merit status, comply with your OHSAS 18001 procedures of assessing regulatory compliance,  validate compliance, and a number of other things. While this list is hardly all inclusive, it gives a good idea of the scope of a safety audit.

The reason a safety audit can help customers with so many different needs is that a good third party safety audit will cover a multitude of areas. First and foremost, the safety audit will review any hazardous assessments for specific health and safety programs. This will ensure that your company is properly handling all known hazardous assessments as per the latest OSHA and state standards. Next, an audit team will conduct a complete “wall to wall” safety inspection. This will help your company to find areas of non-compliance, so that you can fix the issues before someone gets hurt unnecessarily. Then, the auditors should review all accident investigations, in an effort to identify areas of potential concern and to fix any problem areas. Finally, an audit team should review employee involvement and safety training, to ensure that the entire team understands their role in keeping the workplace safe.

With all of this data, an audit company can then create an Action Plan to bring your facility up to code. In addition, as per OSHA policy, this Action Plan can be used, should OSHA come to investigate your facility, as a show of good faith, and help you to avoid citations for any incidents found during the audit which you are in the process of fixing.

PFSafety has a certified team of professionals who will ensure that your business is up to code. If you are ready to get serious about safety, contact us so that we can begin developing your audit plan today.

OSHA Compliant Visual Lockout Procedures

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There are many ways to ensure safety and compliance, regarding your written lockout procedures. You can maintain a filing in-house, and become an expert on OSHA standard 1910.147. You can hire a specialist onto your payroll, and pay them to maintain this for you. Or you can hire a company, such as ours, to run this for you. It is, ultimately, your decision, but you must do something.

What these written lockout procedures must cover, is “the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees.” (1917.147 (a)(1)(i)) So, this standard is serious in regards to employee safety. Unfortunately, the standard can be cumbersome, and it can be difficult to keep track of which machines require which written notices, which can often make it difficult to stay in compliance, and can open your facility up to potentially unsafe environments.

The key to creating a solid, compliant, and safe procedure is that it must: “clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance.” (1917.147 (c)(4)(ii)) Further, it must specify steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy; specify steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them; and this must be tested at least annually.

This is but a brief overview of what is required, and how it should be maintained. We at PFSafety can walk you through the entire process, get you up to speed, and help you stay safe and cut costs with annual audits. Click here to learn more about the requirements and the process.