Monthly Archives: February 2013

Fire Protection (29CFR1910.155)

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Fire protection is obviously an important part of any Safety and Health Management System. Fires can devastate a business and create serious perils for employees. This is why OSHA created standard 1910.155, which covers fire protection. This standard lays the groundwork for an effective method of protecting your employees and place of work in the event a fire breaks out by defining what equipment should be in place and what steps should be taken should a fire start.

The standard discusses what equipment qualifies as “approved” and what does not. To qualify as “approved,” an item must be certified by a nationally recognized testing laboratory, have been tested by a Federal agency and found to be compliant with the National Fire Protection Association Fire Code, or must be custom made and have test data available to inspectors (1910.155(c)(3). If these are devices which can be used by employees, and are not automatically triggered (i.e. sprinklers), they must have proper signage stating where they are.

It goes on to discuss various potential hazards, including fire classifications and other potentially lethal issues resulting from fires. It then discusses how to protect your employees from these fires. But at the heart of any good fire protection plan is a firm auditing schedule. Without proper third party safety audits, you run the risk of keeping outdated equipment in use in your facility, or of being out of compliance without ever realizing. Or, worse yet, having an unacceptable evacuation plan, which could severely limit the effectiveness of your fire protection plan.

If you have any questions about fire protection and standard 1910.155, please feel free to contact us. And if you have anything to add about fire protection, please leave a comment.

Bloodborne Pathogens (29CFR1910.1030)

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If you are in an industry that deals with blood or the potential exposure to blood, protection against bloodborne pathogens needs to be a top priority. OSHA has developed a standard, Standard 1910.1030, which regulates bloodborne pathogens. This standard explains what qualifies as a bloodborne pathogen, what steps need to be taken to prevent exposure, what to do in the event there is exposure, and how to track and monitor exposures. All of this information must be compiled into an exposure control plan.

The first step in prevention is ensuring correct personal protective equipment is worn. For work with blood, this would be gloves, gowns, laboratory coats, face shields or masks, eye protection, mouthpieces, resuscitation bags, pocket masks, or other ventilation devices. Personal protective equipment must not allow blood or other potentially infectious materials to pass through and reach your employees or their clothing. Personal protective equipment is the primary line of defense against the spread of infectious diseases, and must be properly utilized.

In the event there is an exposure incident, there must be a tracking and monitoring process in place. The process must include incident evaluation and medical evaluation. The incident evaluation must include documentation of what happened and how the exposure happened. The medical evaluation must include blood testing and any relevant medical or psychological treatment.

You also need to consider how you properly dispose of waste items, what signage you have, annual audits, training, and how you keep your records. If you have any questions about maintaining an exposure control plan for bloodborne pathogens or the specifics of standard 1910.1030, please contact us. If you have anything to add about bloodborne pathogens, please leave a comment.

Compressed Gas Cylinders (OSHA 29CFR1910.101)

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There are countless industries which use compressed gas and compressed gas cylinders for business. If yours is one of them, then you undoubtedly have come across OSHA standard 1910.101. This standard regulates compressed gases and the handling of compressed gas cylinders. It regulates how to inspect cylinders, how to fill cylinders, how to dispense of compressed gases, what signage is required, and how to store and catalog compressed gas cylinders. It is an extremely important standard, but also an extremely easy standard to have an issue with on an audit.

Employees are expected to regularly review gas cylinders under their control to ensure they are being stored in a safe place. This is a quite subjective and vague explanation, but to get a better explanation, OSHA refers you to the Department of Transportation to review their regulations on hazardous materials. If you need further clarification, you are directed to the Compressed Gas Association Pamphlets C-6-1968 and C-8-1982.

For the handling, storage, and utilization of compressed gases in portable tanks, rail tankcars, cylinders, or motor vehicle cargo tanks, you are referred to the Compressed Gas Association Pamphlet P-1-1965. If you need information about safety relief devices, such as pressure relief devices, you are further referred to Compressed Gas Association Pamphlets S-1.1-1963 and 1965.

If you need help sorting out your OSHA compliance, or updating your signs, please review our audit services and safety signs store, then contact us. If you have anything to add about compressed gas cylinders, please leave a comment.

Means of Egress (29CFR1910.37)

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Evacuation routes are at the cornerstone of any Safety and Health Management System. This is because, if it is needed, your evacuation plan is what allows your employees to get out of a potentially lethal circumstance. Previously, we covered the actual evacuation route, how it should be displayed, how it should be written up, how many evacuation points are required, as well as the basic requirements of the egress points, all of which is outlined by OSHA standard 1910.36. Equally important, however, is the maintenance, safeguards, and operations features for the exit routes. OSHA has also set a standard for these requirements, standard 1910.37.

Your primary concern for an exit route should be that danger is minimized to employees who need to utilize the route. This means there should be no explosives or flammable objects in the way of the egress point, routes should be directed away from hazard areas, routes should have adequate safeguards in place (sprinkler systems, fire doors, exit signs, etc), and routes should be free and unobstructed. Once you have ensured your routes are safe and clear, you need to review the lighting and markings to ensure they are adequate and appropriate.

After you ensure the evacuation route is secure and well documented, you must ensure that fire retardant paint is properly maintained and the alarm system is operable. Should you have any construction or repairs to your facility, you need to ensure your evacuation routes are maintained throughout the project.

If you have any questions about maintaining a means of egress, or if you need proper signage, please contact us. If you have any other tips for maintaining an evacuation route, please leave a comment.

Safety Visuals

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Safety visuals are an important part of your Safety and Health Management System. They notify individuals of where various things are in the event of an emergency and procedures for handling an emergency situation. OSHA sets standards for these visuals in various procedures, but it is important to have a unified system in place to ensure all visuals are up to code and are properly tracked and updated as needed.

The first step in setting your system is to learn which visuals are needed where. Visuals include everything from detailing where fire escapes and fire extinguishers are to the proper use of emergency doors or stairwells. So you need to evaluate your workspace and determine which standards apply to you, and thus which visuals you need to incorporate into your facility.

Next, you need to find the actual visuals you want to use. To do this, you should find a qualified company who can discuss the visuals you need and how to best display them. Once you order your visuals and place them, it is often a good idea to have a third party safety audit, to both ensure you have all of the visuals you need and to ensure they are properly placed.

Once your audit is complete and you are up to speed, you should keep track of your visuals, make sure they are not damaged, and make sure you change when OSHA standards do. Annual safety audits can help you keep track of changes that you miss, providing an extremely helpful service.

If you have a need for a comprehensive safety visual review, or if you feel it is time to update some old signs, please contact us and we will get you up to code. If you have any suggestions for others on what to look for in safety visuals, please leave a comment.

Machine Guarding

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Unsafe machinery is one of the most serious potential hazards for employees. injuries caused by faulty machinery or machinery used improperly can be critical or even fatal. This is why OSHA instituted Standard 1910.212. This standard outlines the safety requirements for machine guarding, giving you a series of steps to take to ensure your machinery is safe.

First, you need to determine which of your machines require guarding. This is any machine which presents a potential hazard. These hazards can include: point of operation, ingoing nip points, rotating parts, flying chips, or sparks. If you have any machines with these or other hazards, you need to ensure you have adequate guarding in place.

Should you have any of these hazards, you need to ensure you have the correct machine guarding in place. OSHA sets some basic guidelines for what type of guarding is required for various potential hazards. For instance, “Revolving drums, barrels, and containers shall be guarded by an enclosure which is interlocked with the drive mechanism, so that the barrel, drum, or container cannot revolve unless the guard enclosure is in place.” (1910.212 (a)(4)) Further, you need to ensure that any machine guards are affixed to the  machine if possible. If not possible, the guard must be secured elsewhere, but in such a way that the guard does not create an additional hazard.

It is important to also put in place accurate signage explaining how to safely use your machinery. To ensure your signage and machine guarding are up to code and to ensure maximum efficacy, it is important to have annual third party safety audits, so that trained professionals can look over your facility. If you have any questions about machine guarding, safety signs, or third party safety audits, please contact us. If you have anything to add about machine guarding, please leave a comment.

The Importance of Safety Audits

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Safety audits allow you to protect your business from potential safety hazards. A good audit will include a wall to wall inspection covering your machines, tools, personnel, training, systems, accidents, hazards, and processes to ensure you know all of your hazards and are following all relevant OSHA standards. They provide a secondary defense against OSHA, helping your safety team to overcome audit difficulties.

Without annual safety audits, you do not have an outside set of eyes verifying the accuracy of your Safety and Health Management System and the procedures you have in place to mitigate risk from worksite hazards. You also do not have anyone making sure you remain up to code as standards change year to year. Without this secondary verification, you are placing an additional burden on your safety team. No matter how qualified your safety experts are, it is always important to have someone else review their work; someone who is impartial and removed from the situation.

And if that isn’t enough, it is also a requirement of OSHA. OSHA requires a third party safety audit annually. Without the annual audits, you will be in violation of OSHA should they audit you. OSHA audits are hard enough, there is no reason to give them a free citation.

Should you have any questions about safety audits, their importance, and how they can benefit you, please feel free to contact us. If you have any advice on what to look for in a third party safety audit company, leave a comment.

Parts of a Safety and Health Management System

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When evaluating your safety procedures, it is best to start with your Safety and Health Management System. If you do not have a Safety and Health Management System established for your business, it is crucial to incorporate one. These systems give you a central system to manage all aspects of safety for your business, which helps you to ensure compliance with OSHA.

The core elements of an effective Safety and Health Management System are: worksite analysis; hazard prevention and control; training for employees, supervisors, and managers; employee involvement; and commitment from management. By effectively implementing these elements into your system, they will become a core competency of your business, and thus an integral part of day to day business, ensuring you are consistently compliant.

If these parts are not all currently in your Safety and Health Management System, it is time to update your system. When updating or establishing a system, make sure you start with a serious worksite analysis. It is recommended you do this through a third party audit; professionals can often find hazards that your safety team has overlooked. Many auditing companies will also help you through the rest of the process of establishing a Safety and Health Management System.

If you have any questions about the parts of a Safety and Health Management System, or if you would like some information about an audit to get you started on setting up your system, please contact us. If you have any information you would like to add about Safety and Health Management Systems, please leave a comment.

An Emergency Action Plan in Action

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In recent weeks, we have seen horrifying fires, damaging tornadoes, and terrible flooding devastating communities and tormenting business owners. The companies who are handling these potentially destructive disasters best are those with an effective emergency action plan. Thankfully, OSHA created guidelines through standard 1910.38 for you to use as a starting point when developing an emergency action plan.

It is hard to discuss emergency action plans without also discussing evacuation plans. These plans, discussed in OSHA standard 1910.36, require that an adequate route be devised for each part of your facility in the event of an emergency which requires immediate egress. An effective emergency action plan must include provisions for evacuation and to account for employees after an evacuation, so obviously you need to incorporate the evacuation plan within the overall emergency action plan.

Time and time again when we review businesses who have suffered a disaster of one kind or another, we find that the more complete the emergency action plan, the sooner the business is able to resume operations. That is because business continuity is an integral part of the plan, and should be accounted for while creating an emergency action plan. If you ever need to put your emergency action plan into action, you will be glad that you incorporated business continuity into it.

If you have any questions about emergency action plans, or need help in establishing one, please contact us. And if you have anything to add to the discussion of emergency action plans, please leave a comment.

Benefits of Preventative Maintenance

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By properly maintaining your company’s machinery, you can significantly reduce repair and replacement costs on your equipment. You can also help to ensure your machinery will stay up to code, based upon OSHA regulations, and thus help to make certain your facility is a safe place for your employees to work.

Preventative maintenance is, unfortunately, too often overlooked in Safety and Health Management Systems. But to overlook preventative maintenance is to do a great disservice to your company. By following manufacturer recommended maintenance procedures, you extend the life of your equipment. This includes everything from daily lubrications and system cleaning to annual system checks and part replacements. Preventative maintenance also helps to guarantee that all inbuilt safety protocols are fully functional.

If preventative maintenance is not a part of your current Safety and Health Management System, don’t fret. Adding preventative maintenance guidelines is actually quite simple. First, you need to go through all of the equipment in your facility, properly inventorying what you have. Next, you need to go through each device and determine what preventative care is required so that you can track that it is done. Finally, you need to create a preventative maintenance placard for each device to track that your employees are actually doing the required maintenance. If your current system relies upon your employees to remember what devices to service and when, you are leaving yourself open to potential issues from human error. A placard reduces this risk, as employees do not need to remember each system’s maintenance requirements.

If you have any questions about establishing a preventative maintenance program, or if you need placards for your equipment, please contact us. If you have any information on preventative maintenance, please leave a comment.