Portable Tools and Equipment (29CFR1910.241)

As we discussed a few weeks ago, hand tools and equipment are used in nearly every field. And while 1910.242 discusses the safe use of these tools, it does not define what these tools actually are. So to avoid confusion, OSHA also created Standard 1910.241, which clarifies and defines what is, and is not, a hand and portable powered tool or other hand-held equipment as well as what the potential safety risks are with certain types of tools. Understanding these definitions can help any business owner determine how to properly regulate their tools and machinery.

This standard discusses and defines explosive-actuated fastening tools, abrasive wheels, and jacks, as well as all of the potential hazards and safety precautions which can be taken. For some tools, the classification is quite obvious, but for others it may not be clear if these standards are applicable. To help you determine if your tools are governed by these standards, you can either refer back to the standards, and attempt to determine if your tools fit their classifications without qualifying for an exemption to a different class, or you can contact a professional, who can help you classify each of your tools. Either way you decide to classify your equipment, it is also important to remember to include these tools in your annual third party safety audits.

If you have any questions about this standard, or how to properly classify your portable and hand powered tools and equipment, please contact us so that we can help you to better understand these definitions and what you need to do with each different class of tool. If you have anything to add about hand and portable powered tools, please leave a comment.

Annual Safety Audits

Many business owners do not understand why they need annual safety audits, and while not necessarily a requirement by OSHA for every business in every industry, most every business is regulated by a standard which has an annual third party safety audit component. Further, as per Docket No. W-100, voluntary third party safety audits can help prevent citations and fines if violations are found but are being corrected after discovery during a recent audit. Finally, the only way to ensure your business is not in violation of any OSHA standards is to have a professional firm with experience in OSHA regulations review your Safety and Health Management System, as well as your work cite.

When done properly, third party safety audits review every aspect of your business operations. Auditors will review the Safety and Health Management System to ensure your current processes are up to code and to see what additional processes need to be inserted. Based upon your industry, auditors will then compare your daily business practices with OSHA’s requirements, to ensure your employees are following all safety protocol. Auditors will also review training procedures for new hires and annual training for staff members. Finally, the team will do a wall to wall inspection of your facility, as a way to ensure there are no additional hazards which need correcting.

After this process is complete, a good auditor will give you the results of your audit, including where there are deficiencies, and work with you to develop a plan going forward of how you will correct your problems. If these are not the services you are receiving from your current auditing firm, or if you would like to learn more about the benefits of annual third party safety audits, then please contact us. And if you would like to add anything about the benefits of annual safety audits, please leave a comment.

Handling Materials (29 CFR 1910.176)

If you work in an industry which requires the use of mechanical handling equipment, then OSHA Standard 1910.176 is surely a concern for you. Or, at least, it should be. This standard was established by OSHA to govern the proper use of mechanical handling equipment, the storage of materials, and the maintenance of the storage locations. It sets very broad requirements and expects you, as the business owner, to ensure you are in compliance.

First, “Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repair, with no obstruction across or in aisles that could create a hazard. Permanent aisles and passageways shall be appropriately marked.” (1910.176[a]) As you can see from this, ensuring aisles and passageways are clear is an important part of this standard. No equipment or mechanical handling equipment may block aisles and passageways, and permanent aisles and passageways need to be kept clear and properly marked with adequate signage. If you are unsure of what constitutes “adequate,” you might consider hiring a third party to audit your facility, to ensure you are in compliance.

It is also important to remember that the storage and maintenance of materials must not cause a hazard. This means that items stacked upon each other must be properly secured. The location where the materials are held must be kept cure of accumulating materials which can create hazards from tripping, fire, explosion, or pest harborage. Finally, proper signage must be used to mark clearance limits as applicable.

If any of this seems like a potential concern for you and your business, please contact us so we can you ensure you are compliant. And if you have anything to add about Standard 1910.176, please leave a comment.

Medical Services and First Aid (29CFR1910.151)

In the event of an emergency or workplace accident, it is important that employees have quick access to the necessary tools and personnel to help with the problem. For many workplace injuries, quick attention from a knowledgeable professional can be the difference between a minor injury and a serious one. Because of this, OSHA created Standard 1910.151 which governs access to medical personnel for advice and consultation on matters of job site health.

For larger organizations, the expectation is an onsite infirmary or onsite specialists available to help with emergencies and workplace questions. In lieu of that, a nearby infirmary, clinic, or hospital is required. These steps will ensure that adequate and speedy care can be taken to help an injured associate. If none of these other options are available, then it is up to the owner to train a person or persons how to administer first aid. Further, the company is required to carry first aid supplies. It is also the responsibility of the employer to offer eye and body flushes to employees who handle injurious corrosive materials.

The easiest way to ensure you are up to code with Standard 1910.151 is through a third party safety audit or a direct consultation with a qualified third party. Remember, this standard is not only important because failure to comply might result in fines; failure to comply means that an onsite injury will not be properly managed and serious injuries can result.

If you have any questions on Standard 1910.151 or third party safety audits, please contact us. And if you have anything to add about medical service and first aid requirements, please leave a comment.

Walking and working surfaces

In 2011, The U.S. Bureau of Labor Statistics reported that 7.5% of all recordable injuries and illnesses and 14.4 % of all fatal injuries in the private industries involved slips, trips and falls. These statistics are second only to motor vehicles as a cause of fatalities. The National Safety Council’s Injury Facts 2009 edition estimated the average cost of lost time injury was about $43,000 per incident. Slips trips and falls cost the U.S. economy 10’s of billions of dollars annually.

The general duty clause of the Occupational Health and Safety Act mandates that “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards…” OSHA established 1910.21-27 standards to address the safety concerns of walking and working surfaces in the workplace. In compliance with these standards, employers are expected to keep all places of employment, floors, passageways, stairways, and storerooms clean, orderly, in sanitary condition and free from any health and safety hazard.

Floors should be kept clean and dry as far as possible. Employers are required to maintain drainage, platforms, mats or other dray standing places where wet processes are used. Every workplace floor and passageway should be free from protruding nails, splinters, holes, or loose boards to facilitate cleaning.

Aisles and passageways should have sufficient safe clearances for mechanical equipment and should be marked appropriately. Covers and guardrails should be provided where necessary to protect from the hazards of open pits, tanks, ditches, etc. Loads should never exceed the approved structural load of the building floor. Maximum load should be marked and affixed in the appropriate areas.

Every stairway with four or more risers, floor openings measuring 12 inches or more in their least dimension, ladder-ways, skylight or manhole floor openings, all should be guarded by standard railing. Winding stairs should be equipped with handrail offset to prevent walking on all portions of the treads having width less than 6 inches.

All ladders are required to be free from damage and rungs free from grease and oil. The foot of the ladder should be positioned no more than one-quarter of their working length from the top to prevent slippage. Ladders should not be placed on boxes, barrels, or in places where it could block doorways. Ladders should be used only for their intended purpose not as platforms, runways, or scaffolds.

There is no silver bullet solution to slips trips and falls. It takes a proactive management to clean the clutter, create a safety culture, and train and make employees aware and part of the safety program.

Employees should avoid wearing loose shirts and dragging pants. Employees are expected to wear appropriate footwear and be trained to report any unsafe condition such as: uneven surface, worn tiles, loose mats or rugs, hose or chords in the walkways, cracks, holes, missing hole covers, missing guardrail, spilled coffee, oil leak, etc. Employees should be part of the hazard control process.

Many tripping hazards are housekeeping items. Hoses and chords across walkways are continual hazard. Rerouting or using protectors reduce these hazards dramatically. Cleaning spills and leaks right after they occur or reporting unsafe conditions as soon as they are observed should become the practice and concern of every employee.

A workplace safety program should include pre-shift inspections of all work areas to ensure no slip trip and fall hazards exist. Waste containers and spill cleanup materials should be easily accessible. Work areas should be well lit and any burnt lights should be replaced without any delay.

Comply with OSHA for a safer workplace.

Monitoring Lockout Tagout

The monitoring and maintenance of Lockout Tagout procedures is a tough task to ask of your safety team. It requires the team to create, track, monitor, and update the necessary procedures for Lockout Tagout. If any equipment changes, the changes need to be reflected in the procedures. If any staff rollover, the team must ensure that that staff member did not have critical information which is not kept anywhere else.

This task can become a full time job for a team which is probably already maxed out with other day to day safety needs. Luckily, there is now fully customizable software which can track and monitor your Lockout Tagout procedures. This software can be updated as needed to keep up with your company’s changing equipment needs, is fully scalable, and ensures you are up to code with your Lockout Tagout monitoring.

This software can be incorporated into your Safety and Health Management System and become a key component of your annual third party safety audits. By utilizing third party software to monitor and track your Lockout Tagout procedures, you are taking the onus off of your safety team and placing it upon someone else, lessening the burden you place upon this team.

If third party Lockout Tagout monitoring sounds like something that can help you to more effectively run your business, please contact us so that we can help you to better understand our product. And if you have anything to add about Lockout Tagout monitoring software, please leave a comment.

Identification of Piping (ANSI/ASME A13.1)

For many industries, piping which carries hazardous materials throughout a facility are a necessary evil. To help employees identify the materials flowing through these pipes, the piping must be properly labeled. This will both make employees aware of the materials flowing around them and, in the event of a leak or other problem, help employees or emergency personnel quickly identify what potential hazard exists. To make this labeling process simpler, ANSI/ASME A13.1 was created. This program creates a universal practice for labeling piping, including a color coded system which allows employees to identify the materials in pipes, even if they can not read the labels.

The color coded system has 10 unique color schemes, identified by the background color and the color of the writing. The system was updated in 2007, however some companies are still using the pre-2007 system. For those companies which are, it might be time to update, as your facility can lead newer employees to misrepresent hazardous materials if they report the labels to a third party in the event of an emergency. The quickest way to do this would be to bring in a professional organization who focuses on workplace safety.

ANSI/ASME A13.1 also covers the requirements of what is on the labels and how big the lettering needs to be. The labels should be short and concise, and have an arrow pointing in the direction of the flow. The lettering should be at least 1/2 inch high, and needs to increase in size based upon the diameter of the pipe.

If you are unsure if your facility has updated its piping labels, or if you would like more information on the exact requirements for your facility, please contact us so that we can assist you in creating a safe work environment for your employees. If you have anything else to add about the identification of piping as determined by ANSI/ASME A13.1, please leave a comment.

Industrial Trucks (29CFR1910.178)

Powered industrial trucks are used on a daily basis by many companies. Most employers don’t think twice about the trucks after they are purchased, and no employees give a second thought to the safety of a piece of equipment they use every day. Unfortunately, that lackadaisical approach to industrial trucks has lead to countless workplace injuries and OSHA fines. To combat workplace injury around these powerful machines, OSHA instituted Standard 1910.178 which covers the fire protection, design, maintenance, and use of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines (1910.178(1)(2)). So, if you utilize any of these trucks at your workplace, you might want to ensure you are using them properly.

This standard requires that all trucks be used as intended by the manufacturer, with no modifications, and with all preventative maintenance properly performed. If you do modify the trucks in any way, you need to receive written consent from the manufacturer, which ensure the modification does not make the truck unsafe. You also need to ensure any trucks utilized are up to code based upon the American National Standard for Powered Industrial Trucks, Part II, ANSI B56.1-1969. Once you ensure your trucks are approved, you must identify that they have been approved with a label or tag stating their approval. There must also be official markings stating the truck is approved for fire safety purposes based upon the 11 designations defined in OSHA 1910.178. Then, you need to ensure all designations are listed in the correct locations as outlined in the standard.

Next, you need to look at how your trucks are being used. Most trucks have safety guard requirements, based upon the size and type of truck. You also need to consider how the fuel and batteries are handled and stored. Depending upon the type of truck you use, there might also be regulations around the brakes and wheel stops you have in place. Finally, you want to ensure that your operators are fully trained and competent in the use of the industrial truck they are driving.

If you have any questions about this standard and how it relates to particular industrial trucks your company uses, please contact us. Should you have anything more to add about standard 1910.178, please leave a comment.

Hazard Communication (29CFR1910.1200)

If you work in an industry that handles hazardous materials, it is important to understand the laws around communicating the potential hazards of said materials. OSHA created Standard 1910.1200, which must be followed when labeling and classifying hazardous materials. And while most companies certainly consulted this standard upon creating their Safety and Health Management System, many have not looked back since. Unfortunately, there was a big update last year which changed this standard to bring it up to code with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals, Revision 3. This was the first major revision since 1994 to this standard, and has left many businesses out of compliance.

This standard is extremely specific about how to classify hazardous materials, how to identify hazardous materials, and how to communicate information and appropriate protective measures regarding hazardous materials to employees. This standard applies to laboratories, wholesalers, manufacturers, importers, warehouses, retail stores, and anywhere else hazardous materials might be found. The standard defines what a hazardous material is, what needs to be on the labels, the types of labels required, and what needs to be communicated to employees. It also explains what needs to be included in the written hazard communication program which you develop for your employees. Finally, it discusses what is not a hazardous material, and when hazardous materials are exempt from all or part of this standard. Because of the complexity of this standard, and how it is situated to uniquely handle many different industries differently, it is important that this is a focal point of your annual third party safety audits.

If you are unsure if you are still up to code given the recent changes, then please contact us so that we can further discuss this standard as it relates to your business. And if you have anything to add about the recent changes to hazard communication guidelines, please leave a comment.

Compressed Gas Cylinders

Many industrial operations require the use of compressed gases. Compressed gas cylinders pose serious safety risk because they have the potential of exploding, becoming flying projectiles or the control valve may become a bullet if not installed properly. The gas could suffocate, poison, or cause serious health problems if leaked into the surrounding air depending on the type of gas contained in the cylinders.

Gases could be flammable, explosive, corrosive, poisonous, acidic, reactive, or combination of hazards.

It’s necessary to carefully handle, use and store the compressed gas cylinders, carefully use the regulators, which control the compressed gas flow, and carefully choose and identify the pipes used to transport the compressed gases.

Due to their potential safety and health hazards, OSHA regulated the handling and use of compressed gases through its 29 CFR1910.101 standard setting guidelines to ensure workers safety in the workplace. The standard refers to the Compressed Gas Association Pamphlet P-1-1965 for the in-plant handling, storage, and utilization of all compressed gases cylinders. The OSHA standard also refers to the Hazardous Material Regulations of the Department of Transportation (49 CFR parts 171-179 and 14 CFR part 103) for visual and other inspections of the compressed gas cylinders.

Compressed gas cylinders must be clearly identified for their contents by name. If the gas cylinder contents are not identified or the cylinder content label is not legible, the cylinder should be marked “content unknown” and returned immediately to the supplier. The labels should be color coded to distinguish the hazardous gases. Always read the label and refer to the MSDS for the gas being used before handling or using compressed gases.

No attempts should be made to repair compressed gas cylinders or valves. Valves are gas specific and should be compatible with the fittings. Valves should be free of damage at all times and should not be used to lift the cylinder.

Cylinders should never be rolled or dragged. When the cylinders are not in use, the valves should be kept closed. Empty cylinders should be marked as such with the valve closed and returned to the supplier as soon as possible.

Proper respiratory protection should be made available when toxic, poisonous, acidic or alkaline gases are handled or used. Emergency eyewash must be present in areas where corrosive, acidic, or alkaline gases are present.

Cylinders should be stored in dry, well-ventilated rooms, and should be properly secured at all times to prevent tipping or accidentally knocked over. They should be stored away from walkways, doors, exits, etc. and away from any source of spark, heat or flame. Cylinders should be grouped by type separating the full and empty containers. Signs should be posted in areas where compressed gases are stored, identifying the substance and the appropriate precautions. The storage room should be properly ventilated and fire extinguishers should be made available with “No Smoking” signs posted where flammable gases are stored.

All gas lines leading from a compressed gas supply should be made of a material compatible with the type of gas used and clearly labeled to identify the gas.

Only properly trained personal should handle compressed gases.