Auditing Lockout Tagout Procedures

Creating lockout tagout procedures is never an easy task; it can be difficult to understand OSHA Standard 1910.147, confusing to maintain the procedures, and time consuming to update lockout tagout procedures. But something you can do to save some time and help protect your employees is to create an auditing schedule for your lockout tagout procedures. The auditing can be done in house or with the help of a qualified third party lockout tagout auditing firm, but it should always include certain, basic things.

For starters, the audit should review current OSHA policy to ensure nothing has changed since the last review. It is likely that you will be out of compliance is the regulations changed, and is the easiest way to find yourself facing a hefty fine from OSHA. The audit should also review what changes have happened within your company since the last audit. If any machinery or relevant personnel have changed, you will want to see what, if any, impact these changes have on your lockout tagout procedures. Finally, you want to inspect your placards and other associated visuals. If they are damaged, worn, or out of date, they need to be replaced.

But based upon your specific company needs, there can be many other things required during the audit, as well. For this reason, many companies hire a third party to maintain their lockout tagout procedures. And while this helps to ensure the company remains in compliance, it can also become quite expensive, and takes the company out of control of their own procedures.

For this reason, we created our Factory Solutions Software. It is an online program which tracks and monitors your lockout tagout procedures. It is fully customizable, fully scalable, and can be updated anywhere internet is available. It will notify you if there is a problem, and will help you in updating your procedures. So it keeps you in control, but gives you the peace of mind knowing your procedures are watched by a qualified third party lockout tagout auditing firm. It also serves as constant, real-time auditing, instead of moment-in-time auditing you get with a physical audit. When combined with physical, on-site third party safety audits, Factory Solutions Software helps to create the safest work environment possible for your employees.

If you have any questions about third party safety audits or our Factory Solutions Software, please contact us. And if you have anything to add about auditing lockout tagout procedures, please leave a comment.

OSHA Proposes Over $2.3M in Fines for Olivet Management, LLC

The US Department of Labor’s Occupational Safety and Health Administration has cited Olivet Management, LLC for $2,359,000 for safety violations relating to asbestos and lead hazard exposure. According to OSHA, the company exposed its own employees, as well as employees for 13 contractors, to asbestos and lead during cleanup operations of the Harlem Valley Psychiatric Center in the Wingdale section of Dover Plains, NY.

 

“Olivet knew that asbestos and lead were present at this site, yet the company chose to ignore its responsibility to protect its own workers and contractors,” said U.S. Secretary of Labor Thomas E. Perez. “The intolerable choice this company made put not only workers, but also their families, in danger.”

In total, Olivet was cited for 45 willful violations and 1 serious violation. Of the 45 willful violations, 24 address instance-by-instance exposure of workers to asbestos and lead hazards.

As you can see, lead and asbestos violations can quickly compound, leading to serious fines. If you work in an industry that involves asbestos, lead, or any other toxic substance like these, it is imperative you have sound procedures in place for the dissemination of policy, employee education, and adequate testing. If you do not have procedures in place, or if you have not reviewed them recently, it might be time to consider updating your safety and health management plan. And if you are going to go through this process, it is usually advisable to consult an occupational safety and health advisory firm.

If you have any questions about establishing procedures for asbestos or lead management, please contact us. If you have anything to add about these citations or about asbestos and lead exposure, please leave a comment.

Cost Effective Lockout Tagout Solutions

One of the biggest complaints in the lockout tagout industry is cost. For most, it is monetary cost, as it can grow expensive to create and maintain lockout tagout procedures if you employ a third party lockout tagout specialty firm. For others, the cost is time, as learning to understand OSHA Standard 1910.147 is difficult, and trying to create effective lockout tagout procedures based upon it without prior knowledge of the standard can be daunting. And for still others, the cost is twofold, as they spend untold time creating their procedures, only to need help from a third party to maintain them.

Fortunately, there are options which cut both the time and monetary costs to a fraction of what they once were. These are options which allow a partnership between a qualified third party lockout tagout specialty firm and the company needing the lockout tagout services. The lockout tagout firm helps the company to create the procedures and to create a plan to maintain them long term with online software, which is fully scalable, fully customizable, and accessible anywhere there is internet.

We offer this service through our Factory Solutions Software. With this software, you can create, maintain, and update your own procedures under the guidance of a premier lockout tagout specialty firm, but do so at a steep financial discount because you are doing it yourself. We can be as hands-on or hands-off as you want, allowing you to find the perfect balance of financial and time costs.

If you have any questions about our Factory Solutions Software, please contact us. If you would like to add anything about cost effective lockout tagout solutions, please leave a comment.

Establishing a Preventive Maintenance Plan

Preventive maintenance plans help to increase the life of your machinery, decrease your maintenance costs, and maintain the efficacy of your safety equipment. But if you do not have a plan in place, it can be difficult to establish one for an existing business. This is because you need to re-catalogue every piece of equipment and every machine in your facility, and find the specific manufacturer’s instructions and maintenance recommendations. Then, you need to couple this information with your existing procedures and any relevant OSHA standards to create your preventive maintenance plan.

A preventive maintenance plan should include procedures for daily, weekly, monthly, and quarterly checks. These routine checks will ensure all parts and processes are functioning properly, fluid levels are appropriate, and there are no unaccounted for faults. These checks will increase the life of the equipment, protecting the company’s bottom line.

Additionally, these plans will create a safer work environment. By continually ensuring that safety mechanisms and equipment are functioning properly, there is no opportunity for faulty equipment to allow workplace accidents.

Finally, these programs can protect you from OSHA violations. If an injury occurs due to a faulty piece of equipment, OSHA will review your maintenance records. Should it become clear that no system is in place to ensure the effectiveness of your safety equipment, that will create a serious problem with OSHA.

If you have any questions about how to establish a preventive maintenance plan, please contact us and we can walk you through the process. If you have anything to add about how to effectively establish a preventive maintenance plan, please leave a comment.

Establishing Evacuation Routes

Evacuation routes are important for every company in every industry. Whether a retail storefront or a large facility that employs thousands of people, evacuation routes act as a final safety procedure which can, and will, save lives. So it is important to consider the ramifications of poorly created evacuation routes when creating your evacuation procedures.

When initially creating evacuation routes, and anytime you update them thereafter, you need to consider OSHA Standard 1910.36 and Standard 1910.37, which govern the creation and maintenance of evacuation routes. These standards should act as a baseline for your evacuation procedures, and can be added to based upon the specific needs of your facility.

Standard 1910.36 focuses on the design and construction of exit routes. This includes how many exits are needed, how many paths to these exits are needed, what kinds of doors must be used at these exits, and the materials which need to be used in the construction of these exit doors and routes. This standard is the standard which helps you create an effective evacuation route.

Standard 1910.37 focuses upon the operational features, safeguards, and maintenance of exit routes. This standard covers paint, lighting, how to proceed when there is construction being done to the evacuation route, door maintenance, and so on. So if Standard 1910.36 helps you create an effective evacuation route, this standard helps you to maintain it.

If you have any questions about how to establish or maintain an evacuation route, please contact us so that we can assist you. If you have anything to add about establishing evacuation routes, please leave a comment.

Changing Lockout Tagout Procedures

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

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

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

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

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.