Permit Entry System for Confined Spaces

Confined spaces are a necessary part of many facilities. These spaces, unfortunately, have the potential to cause serious harm to employees, and are made more dangerous with the presence of other common hazards. To help prevent employee injury, OSHA created Standard 1910.146, which governs confined spaces and establishes the parameters for permit entry systems.

Once a space has been declared a confined space, meaning it is a space large enough and so configured that it is possible for a person to bodily enter and perform work, has limited or restricted means for entry and exit, and is not designed for continuous employee occupancy, an employer needs to determine if it is a permit-required confined space. Permit-required confined spaces are spaces which contain or have the potential to contain a hazardous atmosphere, contain a material that has the potential for engulfing an entrant, has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section, or contains any other recognized serious safety hazard.

If a confined space has any of these additional hazards, a system must be set up to protect the employees; this is done by either creating alternate entry procedures or creating a full permit entry system. Alternate entry procedures are allowed if the only hazard present is atmospheric in nature and if the employer can demonstrate that continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry.

If forced air will not rectify the situation, then a full permit entry system is required. These systems document who may or may not enter the space, when these people may or may not enter the space, how these individuals will be monitored, who will be responsible for monitoring entry into the space, and what safety equipment is required before entry. The space must then be routinely audited to ensure no additional hazards have developed and to ensure that all safety equipment is working effectively.

So if you own a facility which has confined spaces and you have not recently reviewed your permit entry system, it might be time to do so. If you have any questions through the process, please contact us so we can help you through the process. And if you have anything to add about the importance of permit entry systems for confined spaces, please leave a comment.

Creating New Lockout Tagout Procedures

In the world of occupational health and safety, there is not much that is more difficult to

uderstand and implement than lockout tagout procedures. OSHA created Standard 1910.147, which sets basic guidelines and rules relating to lockout tagout, which should act as a blueprint for any lockout tagout procedures created. This standard, however, is extremely complicated and leaves many first timers in a very confused place.

This confusion generally leads to one of three things: the employer either attempts to do it himself, leaving his employees potentially at risk for serious injury or death and the company at risk for sizable fines; the employer hires a qualified third party lockout tagout specialty firm to create the procedures, which creates sizable upfront costs to the company and takes control out of the hands of ownership; or the employer finds an online “cheat sheet” and hopes the material is accurate.

Thankfully, a new option has developed over the last few years which acts as a hybrid of all three; you can remain in control of your lockout tagout procedures, under the supervision of a true powerhouse in the lockout tagout arena, and use easy to understand documents to guide you. This is accomplished through our Factory Solutions Software, which is a fully customizable, fully scalable, and is available to you anywhere you have an internet connection. We ensure the program is up to date on all regulations, and we ensure your illustrations are accurate, but you can make changes as you need without the hassle of consulting a third party, delaying your business for days waiting for an approval.

If you would like more information about our Factory Solutions Software, please contact us. And if there is anything else you would like to add about creating new lockout tagout procedures, please leave a comment.

OSHA Proposes $210,000 in Fines for Rasi Laboratories

The Department of Labor’s Occupational Safety and Health Administration inspected the Somerset, NJ facility of Rasi Laboratories, Inc. in August of 2012. In October of 2013, OSHA came back to review the progress of the required changes from the initial inspection. Inspectors found that many of the problems uncovered in 2012 were not yet fixed. This inspection led to proposed penalties totaling $210,000.

“This employer continues to endanger its workers by failing to correct hazardous conditions and failing to implement an injury and illness prevention program,” said Robert Kulick, OSHA regional administrator in New York. “Such disregard for worker safety is unacceptable.”

In August of 2012, OSHA issued seven serious violations totaling $23,100 in fines. When OSHA inspectors returned, they found that the company had failed to abate hazards relating to implementing a continual and effective hearing conservation program for workers exposed to noise above 85 decibels. It also failed to develop and implement a lockout/tagout program to protect workers from dangerous machinery during servicing or maintenance and train employees on proper procedures.

What we can learn from this is that if your company is audited by OSHA, it is important to properly implement any corrective actions deemed necessary by OSHA. If you are having difficulty doing this or if you have any questions about the efficacy of any plans you have put in place, it might be a good idea to consult a qualified occupational safety and health auditing firm to assist.

If you have any questions about updating your safety and health programs at your facility, please contact us. If you have anything to add about this case or about working with occupational safety and health consulting firms, please leave a comment.

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.