Tag Archives: ISO certified

Challenge of OSHA’s HazCom Standard Rejected in Appeals Court

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The American Tort Reform Association asked the court to review Paragraph (a)(2) of the newly revised Hazard Communication standard. This paragraph states that the new chemical labeling regulations do not preempt failure-to-warn claims filed in state courts.

Now, this ruling probably will not have much of any impact on business owners. But what will have an impact are the HazCom standard updates, which just cleared a huge hurdle now that this review has completed.

OSHA is updating its Hazard Communication standard to be in line with the chemical labeling system used by the United Nations. And many of the changes are significant enough to warrant a review of any procedures in place regarding Hazard Communication. The primary changes will revolve around the actual labels utilized in the work place and on the job site. So when reviewing your procedures, please ensure that you pay special attention to these portions of the standard.

If you are concerned with how these changes will impact your business, it might be a good time to consult an occupational health and safety management firm to review your current procedures and to guide you through the pending regulatory changes. The sooner you begin to formulate a plan and implement changes, the smoother your transition will be. And in this case, OSHA will be looking for companies which do not have a smooth transition.

If you have any questions about the regulatory changes upcoming to HazCom or about the recent legal decision, please contact us. And if you have anything to add about the recent court decision, please leave a comment.

Forever 21 Fined Over $236k by OSHA for Repeat Violations

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OSHA inspectors audited Forever 21 locations in Paramus and Manhattan in July after receiving complaints alleging violations. The results of those audits have come in, with proposed penalties to Forever 21 in the amount of $236,500. These fines were for six repeat citations and one serious citation.

The repeat citations, which are citations issued when a substantially similar violation is found at any other facilities owned by the same employer within the previous 5 years, were for: obstructed exit routes, fluorescent lights with no covers, a fire extinguisher that was not mounted and readily accessible, and stored material that was not secured against sliding or collapsing. The obstructed exit routes and fluorescent lights with no covers were citations at both facilities, while the other two were only at the Paramus location.

The serious citation, which is a citation issued when there is “substantial probability that death or serious physical harm could result and the employer knew, or should have know, of the hazard,” was issued because the Manhattan store was not kept clean and orderly.

This is a prime example of why companies need to have all of their facilities audited by professional third party occupational health and safety experts. Many employers do not think of retail spaces as a place where OSHA will come knocking to audit, but it is important to remember that OSHA will take complaints anywhere you have employees working.

If you have any questions about third party safety and health auditing, please contact us. And if you have anything to add about the importance of third party safety audits, please leave a comment.

Finding The Right Firm to Help With Lockout Tagout Procedures

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We are often called to help companies update existing or establish new lockout tagout procedures after they have had an issue with their existing procedures. Many clients have already hired a third party to create their initial procedures, but the procedures were either created incorrectly or were not created in such a way that they could account for changes. In these situations it can often be far more difficult to fix the incorrect procedures than it would have been to simply establish new procedures the correct way.

For these reasons, we always recommend credentialing the firm which will help you to establish your lockout tagout procedures. There are a number of ways to do this, including checking what certifications (if any) the firm has, finding out about the work history of the firm and its employees, and asking for references. But at the very least, it is important to question the person who will be auditing your facility and developing your procedures about lockout tagout in general and your facility specifically, focusing on how you will be able to update your procedures in the future, should your needs or regulations change. It is amazing how little unqualified specialists know, and you can usually sniff that out.

If you have any questions about your existing lockout tagout procedures, or if you are interested in establishing new procedures, please contact us and we can explain how our process ensures compliance for you now and in the future. If you have anything to add about the importance of establishing lockout tagout procedures correctly the first time, please leave a comment.

Auditing Lockout Tagout (LOTO) Procedures

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After establishing Lockout Tagout procedures, it is important to maintain them. A key component of maintaining lockout tagout procedures is to routinely audit them. These audits should include a full review of the current lockout tagout procedures, a review of any changes since the last review, and a review of the machines covered in the procedures. Additionally, it is important to review the training plan, how the procedures are made available to employees, and how management is held accountable for ensuring lockout tagout compliance.
When reviewing the lockout tagout procedures, it is important to be mindful both of changes to the facility and personnel, as well as changes to the OSHA standards. Both of these components are vital, as you will not be in compliance if either piece changes and is not accounted for in the procedures.
When reviewing the changes, it is important to understand the “why” behind the change as much as understanding the actual change. Many clients will update their procedures correctly, meaning the changes are in compliance with OSHA standards, but the changes are not correct for the need, so the company is still out of compliance.
And finally, the training and availability are as important as the procedures themselves. If an effective plan is not in place for employees to learn the procedures, then they will not be properly followed, and the hazards will still be present.
If you have not recently had your lockout tagout procedures audited, please contact us so that we can help you determine if you are in need of a review. And if you have anything to add about the importance of auditing lockout tagout procedures, please leave a comment.

Arc Flash and Shock Monitoring

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Establishing a competent and compliant arc flash and shock hazard plan can be extremely difficult. Every machine in a facility needs to be tested, the entire circuit needs to be tested, and the results need to be compared against the very difficult to understand NFPA 70E. And there is no real OSHA standard to compare NFPA 70E to, so the only point of reference is the document itself or third party documents, which may or may not be credible.
But after you overcome the challenge of establishing an arc flash and shock hazard plan, there is still a constant need to monitor the plan. As machinery, employees, or regulations change, so too do your plans need to change. And each time a change is made, the entire plan needs to be reworked to ensure nothing else is out of compliance from the changes.
To help avoid difficulties with changes, many companies hire a professional safety and health management company to monitor and update their plans. But when hiring a company, you need to ensure you are hiring a qualified company with auditors who are properly prepared to help your business transition into the future, no matter what changes may lay ahead. In order to properly vet auditors, make sure to not only ask them questions about what to do now, but also how to handle potential future changes. If they have difficulty in articulating how to compensate for potential future changes, it might be a good idea to look elsewhere; you do not want someone reviewing your arc flash and hazard plan who cannot manage it indefinitely.
If you have any questions about arc flash and shock monitoring, please contact us. And if you have anything to add about the importance of arc flash and shock monitoring, please leave a comment.

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.