Tag Archives: Safety signs

Creating Efficient Lockout Tagout Procedures

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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

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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

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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.

Confined Space Program

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An average of almost 2 workers per week die from confined space accidents. Most of these fatalities occur as a result of oxygen deficiency or the inhalation of toxic substances. In 2013, these two accident types accounted for 91% of all confined space accidents. With a properly developed confined space program, every single one of those fatalities could have been avoided.

When developing a confined space program, you need to first review OSHA Standard 1910.146. Standard 1910.146 sets the minimum safety requirements for all things confined spaces. It defines what a confined space is, defines in what situations a permit entry system is required, what to do in the event a hazardous atmosphere is present in the confined space, and how to properly maintain the space.

With the definitions and directions from Standard 1910.146 in mind, it is time to create your confined space program. In order to do this, you will first need to assess your facility to determine how many confined spaces you have. From there, you need to assess the individual spaces and, based upon the requirements set in Standard 1910.146, determine if a permit entry system is required, or if there are any special circumstances surrounding your spaces.

From there, you need to create procedures which take into account personal protective equipment, signage, a permit entry system (if applicable), a toxic substance plan (if applicable), and what your rescue plan is in the event of an emergency. Finally, you want to ensure your plan is able to adapt to future changes, meaning that you have someone monitoring Standard 1910.146 in case of updates and that you have provisions for how to add additional regulations should additional confined spaces or changes to your current confined spaces need to be accounted for.

If you have any questions about creating or updating a confined space program, please contact us. If you have anything to add about how to create a confined space program, please leave a message.

OSHA Compliant Lockout Tagout Procedures

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Creating OSHA compliant lockout tagout procedures can be more difficult than it originally seems. We have worked with many clients who initially planned on creating their own lockout tagout procedures, only to get halfway through the project and need to reach out for help.

So whenever we are advising a client who needs new lockout tagout procedures, we make several recommendations. Number one, let a qualified lockout tagout expert create the procedures, but make sure you are involved in the process. This way, you will understand how lockout tagout works, why your procedures are created in the way they are, and you will be more able to properly enforce the procedures.

Number two, learn OSHA Standard 1910.147. Whether a client ultimately decides to work with us or try it alone, it is important they understand the standard, at least superficially. But the more you understand the standard, the more effectively you can monitor your procedures and enforce they are being followed.

And number three, have a plan in place to monitor and update the procedures. If there is nothing in place to help you prepare for the future, there could be issues down the line if regulations or your business change. One of the easiest ways to monitor and update your system is with software which is designed to survey and audit your lockout tagout procedures. This type of software allows you to make changes or updates to your existing procedures while maintaining your compliance.

If you have any questions about creating or maintaining lockout tagout procedures, please contact us. If you have anything to add about OSHA compliant lockout tagout procedures, please leave a comment.

OSHA Increasing Focus on Tower Safety

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Last week, OSHA issued a statement regarding the surge in cell tower fatalities. In 2013, there were 13 fatalities related to cell towers; that number is more than the two prior years combined. In the first five weeks of 2014, there have already been 4 fatalities. As a result of this increase in fatalities, OSHA is collaborating with the National Association of Tower Erectors to make certain all employers in the industry understand their role in employee safety for those employees who work on cell towers.

“Tower worker deaths cannot be the price we pay for increased wireless communication,” said Dr. David Michaels, assistant secretary of labor for occupational safety and health. “Employers and cell tower owners and operators must do everything possible to stop these senseless, preventable tragedies.”

The majority of fatalities over the last two years have come from falls. In order to help ensure employees are aware of current best practices and industry standards, they have created a new website, which will feature all information including regulatory changes. Many of the fatalities were preventable, but due to poor safety procedures and a lack of training, these individuals died.

If your business works with cell phone towers in any capacity, it is critical that you continue to follow the news regarding these updates. It might also be a prudent time to have your safety and health management system audited, to ensure you are in compliance.

If you have any questions about this release from OSHA or about third party safety audits, please contact us. If you have anything to add about OSHA’s increased focus on tower safety, please leave a comment.

Creating an Evacuation Plan

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Properly created evacuation plans will account for a number of potential emergency conditions. These conditions should be both internal and external, and should consider OSHA Standard 1910.36 and Standard 1910.37. These standards guide you in creating the actual evacuation plan and in maintaining the evacuation routes. Simply pointing employees to the nearest exit will not suffice in a true emergency.

Standard 1910.36 specifically discusses the design and construction requirements for exit routes. This standard covers the number of exits required, the number of paths to said exits which are required, the types of exit doors which must be used, and what types of materials must be used in the construction of exit doors and routes. Based upon your facility and your needs, this standard can help you to ensure you create a truly effective evacuation plan.

Standard 1910.37 discusses the maintenance, safeguards, and operational features for exit routes. This standard sets the guidelines for maintaining the routes established in the evacuation plan. It covers everything from lighting and paint to door maintenance and what to do in the event construction is being done to the evacuation route. So where Standard 1910.36 will help you establish your evacuation plan on paper, Standard 1910.37 will help you to maintain these evacuation routes in the event of a real emergency.

If you have not recently reviewed your evacuation plan or if you do not have a true plan in place, it might be time to have a qualified third party firm review your plans. If you have any questions about evacuation plan reviews or creating a new evacuation plan, please contact us. If you have anything to add about creating an effective evacuation plan, please leave a comment.

Creating Effective Lockout Tagout Procedures

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Creating effective lockout tagout procedures is more of an art than a science. You need to be able to effectively navigate OSHA Standard 1910.147; properly audit your machinery, taking all potential variables into account; create a coherent procedure with this information; and account for future business and regulatory changes. And if you do all of this correctly, your procedures are only good for the time in which your business remains exactly the same; once one variable changes, the procedures need to be updated to reflect the change.

Because of the difficulties with creating effective lockout tagout procedures, most employers rely on qualified third party lockout tagout specialists to create their procedures. A qualified individual who dedicates himself to understanding the lockout tagout regulations can easily assess most facilities and create unique procedures based upon that facility’s needs relatively quickly.

In addition, a qualified lockout tagout specialist will create procedures which account for change. There will be room for change built into the procedures and a plan will be in place for how to account for those changes. Changes can be accounted for in a number of ways, but ensuring there is some plan in place is crucial when hiring a lockout tagout specialist to assist you in creating your procedures.

If you have any questions pertaining to the creation of effective lockout tagout procedures or updating lockout tagout procedures, please contact us. If you have anything to add about the importance of devising a plan for change in lockout tagout procedures, please leave a comment.

OSHA Considering Extending Crane Operator Certification Requirements

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On August 9, 2010, the Occupational Safety and Health Administration issued a final standard in relation to cranes and derricks used in construction work. This standard established new requirements for crane operators working on construction sites. In order to meet these new requirements, crane operators would be required to meet one of four certification or qualification requirements by Nov. 10, 2014. OSHA is now looking to extend that date by 3 years to Nov. 10, 2017.

OSHA has proposed this rule change in order to appropriately and effectively respond to inquiries and complaints lodged by several parties. OSHA does not want a rule change to go in effect while the rule change is still being discussed and does not want to create a negative impact upon the construction industry. There have already been three stakeholder meetings on this issue, and the final date to submit comments on the rule change is March 12, 2014.

What this means for you, is that if your company uses cranes or derricks, you need to keep a close eye on this situation. If you have not already scheduled your crane operators for certification, it is still a good idea to get that process started, as this rule change has not yet been approved. And even if the extension is passed, these operators will still need to be certified in 2017.

If you would like more information on how this rule specifically impacts you and your business, please contact us. And if you have anything to add about the new crane operator certification requirements, please leave a comment.

Compressed Gases

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Compressed gases are utilized across many industries. These gases can come in all types, and can be held in containers of all sizes. For this reason, it can be difficult for a company to properly develop a safety plan pertaining to compressed gases and their storage.

Because of this inherent difficulty, OSHA created Standard 1910.101, which sets minimum requirements for the use, transportation, and storage of compressed gases. In addition, this standard sets guidelines for safety relief devices which must be included on the compressed gas containers.

Unfortunately, OSHA largely hands the issue off to the Department of Transportation and the Compressed Gas Association. For issues pertaining to the storage, transportation, and use of compressed gases, business owners are sent to the Department of Transportation’s Hazardous Materials Regulation (49 CFR parts 171-179 and 14 CFR part 103). This regulation, in turn, covers all hazardous materials, and requires cross-referencing for different compressed gases and different containers.

OSHA then directs readers to the Compressed Gas Association Pamphlets S-1.1-1963 and 1965 addenda and S-1.2-1963 for any questions pertaining to the required safety relief devices for compressed gas containers.

So to initially establish a compressed gases safety program, you must review multiple sources. Then, to ensure continued compliance, you must continually review these multiple sources.

To streamline that process, it is often easier to simply work with a third party occupational safety and health auditing firm which can keep you abreast of regulatory changes while helping to ensure your safety plan is compliant.

For more information on compressed gas storage, use, or transit, please contact us. If you have anything else to add about compressed gases or their related regulations, please leave a comment.