Monthly Archives: June 2013

OSHA 29CFR1910.151 Medical Services and First Aid

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Access to basic medical services and first aid is important in any place of business. It can be a way to prevent a minor injury from becoming something major, and can help prevent a serious injury from becoming disastrous. Any way you look at it, first aid and quick access to basic medical services is of paramount importance to keeping employees safe.

As such, OSHA created Standard 1910.151, which governs medical services and first aid. This standard states that a person must be “adequately trained to render first aid” if there are no infirmaries, clinics, or hospitals in “near proximity to the workplace.” This person must be trained and employed by the employer, and must be available to any employee who faces potential injury at work. The standard goes on to state that “adequate” first aid supplies must be available to the staff.

In addition, this standard governs eye flush and shower devices used in facilities where there is a risk of exposure to injurious corrosive materials. These devices must be readily available to the staff in the event of an accident, and must be suitable to properly cleanse the victim. If you have not recently audited your devices, it might be a good idea to do so, as these devices are not often used, but are extremely important when needed.

If in reading any of the above guidelines you were struck by the vagueness of the standard, don’t worry – you’re not alone. This standard leaves a lot of room for interpretation and has nearly 30 standard interpretation responses listed. And for a standard as small as this one, it makes it one of the least clear standards currently in existence.

So, if you have any questions about the specifics of your facility, please contact us so that we can help ensure you are up to code. And if you have anything to add about the importance of quick access to medical services and first aid, please leave a comment.

Flammable and Combustible Liquids (29CFR1910.106)

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Flammable and combustible liquids pose an obvious threat to employees in any industry which uses them. These liquids must be stored, maintained, transported, and used in very specific ways. If they are not properly handled and combust, the resulting damage can be catastrophic.

But with so many different liquids, containers, means of transportation, piping, valves, and fittings associated with flammable and combustible liquids, it can be nearly impossible to keep track of what the safest way to handle the liquids in each situation is. Fortunately, OSHA developed Standard 1910.106 which sets guidelines for the proper handling of flammable and combustible liquids. This standard relies heavily on the expertise of the NFPA, specifically utilizing NFPA Publication 30 as a foundation for creating the standard.

Standard 1910.106 sets guidelines on both large and small containers, meaning everything from propane cylinders to permanent tanks built into large facilities. The standard specifically discusses how and where various tanks can be stored and how they must be transported, as well as specifics about the containers, such as size and material requirements, and specific safeguards which must be in place.

The standard also sets guidelines addressing the piping, valves, and fittings used for flammable and combustible liquids. These guidelines cover the design, materials used, linings, supports, and testing of these items. Finally, the standard sets requirements around an auditing schedule which must be strictly followed.

If you have any questions about how this standard affects your business, or what to do about specific flammable and combustible liquids at your facility, please contact us so that we can help you set appropriate procedures. And if you have anything to add about flammable and combustible liquids, please leave a comment.

Heat Stress

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As we approach the peak of summer, heat related injuries are becoming a key concern for most business owners in theUnited States. In most of the country, the temperature will begin to hit 80 degrees and higher on a routine basis, and for employees working outdoors or indoors in improperly ventilated and cooled facilities, the chance of a serious injury or even death is rising.

Heat related regulations are littered throughout OSHA’s standards, but heat stress also falls directly in the original Occupational Safety and Health Act, under Section 5(a)(1), which states, “employers shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” And OSHA has made clear that this broad requirement does, in fact, apply to heat related injuries.

But unlike other hazards, such as evacuation plans and arc flash analysis which have clearly defined standards, it is hard to make blanket suggestions to keep employees safe from heat stress. As a general rule, it is important to have regular and routine breaks available to employees, where they are at least afforded shade, if not access to air conditioning. Access to water or other drinks designed to rehydrate is another important step to take; dehydration is one of the most common catalysts to heat stress. Finally, consider restructuring the work schedule to have high physical demand jobs performed early in the day or later in the evening, when it is cooler.

Ultimately, to properly gauge the effectiveness of your heat stress plan, it is important to have a full audit done on site at your facility. For more information on how an audit would help your company ensure compliance, or to get started, please contact us. If you have anything to add about the dangers of heat stress, please leave a comment.

The Control of Hazardous Energy (29CFR1910.147)

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Standard 1910.147 covers the control of hazardous energy, which is also known as lockout tagout. Lockout tagout procedures are among the most difficult to institute and are even more difficult to maintain as a company changes over time. In 2011, this standard was responsible for nearly 4,000 citations. But, lockout tagout procedures are also crucially important, as a lockout tagout accident generally leads to serious injury or death, and led to 120 fatalities and 50,000 injuries in 2011.

The first thing to consider when setting your lockout tagout procedures is what, exactly, lockout tagout is. Per OSHA, lockout tagout procedures cover “the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees.” (1917.147 (a)(1)(i)) What this means is that any machine which can harm an employee at start up, or any other time through stored energy, must be included within the procedures. Employers must determine all of the isolation points within all of these machines, create standards to control this hazardous energy, and properly label the offending machines.

Unfortunately, it can be difficult to determine the isolation points, especially given the sometimes cryptic nature of this standard. It is for this reason we always recommend contacting a professional when establishing or updating procedures. Depending upon your particular needs, a consultation might suffice or a full audit might be required to ensure compliance. But whatever your need is, this is definitely one of those hazards where it is better to be safe than sorry.

For more information on creating lockout tagout procedures, or to schedule an audit, please contact us. And if you have anything to add about Standard 1910.147, please leave a comment.

The Importance of Personal Protective Equipment

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Personal protective equipment is often the only safeguard for employees from potentially serious hazards. This equipment is worn on the body and in some way reduces or eliminates the potential for injury. It is designed to act as the last means of protecting oneself if all other safety measures should fail.

Unfortunately, many employers and employees do not take personal protective equipment seriously enough. Personal protective equipment can be cumbersome to employees trying to work, creating a situation where work takes longer due to restrictive clothing or bulky gloves. Coupled with the feeling that they will not misuse equipment they use on a daily basis, it is all too common that these employees stop using certain pieces of personal protective equipment. Similarly, employers have been known to rely too heavily on safety procedures and systems. But remember, no matter how many secondary systems, failsafes, and other mechanisms are in place, these systems can and do fail.

Another common problem we find with personal protective equipment is the quality of the equipment being used. Gloves, for instance, should not have holes in them and reflective vests should not have the reflectors ripped off from years of overuse. Apathy toward personal protective equipment is a very dangerous threat to everyone.

If you have not recently reviewed your Safety and Health Management System with a keen eye toward the personal protective equipment you are utilizing, it might be time to do it. If you have not updated your system recently, or if you have not reviewed your personal protective equipment, it might be worth contacting a professional organization for help.

If you have any questions about the importance of personal protective equipment, please contact us. And if you have anything to add about personal protective equipment, please leave a comment.

Identifying Piping (ANSI/ASME A13.1)

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It is important to be able to quickly and effectively identify what types of materials are flowing through exposed pipes, and what direction these materials are flowing. It is essential that the system utilized to identify piping is uniform and can be understood by all employees who work in your facility, not just those who work in a part of your facility near the exposed piping on a routine basis. The identification system must also be easy for non-employees to understand; this can include both guests of the facility and first responders, who might be called upon in the event of an emergency.

For these reasons, the ANSI/ASME A13.1 pipe labeling system was created. This system sets uniform requirements for labeling pipes, including the size of labels as well as the size of label print, the colors for the writing and for the background of the labels, and how to properly denote the direction of flow of a pipe. By ensuring your facility is following the requirements established in this system, anyone who enters your facility will be able to quickly identify the severity of materials flowing through pipes, as well as the direction it is flowing. Therefore, if there is a leak or other issue, it will be easier to shut the pipe down correctly and evacuate any relevant areas. And, should there be an emergency situation, anyone near exposed piping will know how to proceed – if it is safe to continue or if they should find an alternate route away from the pipe.

If you have not recently updated your pipe labels and feel it might be time for a review, or if you have any general questions about ANSI/ASME A13.1, please contact us. And if you have anything to add about this topic, please leave a comment.

Occupational Noise Exposure (29CFR1910.95)

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Though often overlooked, damage to hearing through long term exposure to loud noises is an extremely common injury on the jobsite. This exposure most commonly comes from tools, but can come from any one of a number of other processes which provide extreme noise output. If you work in an industry which could expose you or your employees to excessive noise, it is important to be sure your company is following OSHA Standard 1910.95 which defines the parameters for an acceptable hearing conservation program.

The first thing this standard does is lay out exactly what constitutes a high noise area through a table that breaks down standard and atypical sound output via decibel and frequency levels. Next, it lays out how long per day an employee can be exposed to various sound levels before a hearing conservation program must be introduced. Finally, it discusses the details of a hearing conservation program should you have employees who require admission into such a program.

These programs require strict monitoring, requiring you to check hearing capabilities on a routine and regular basis. These tests must check to ensure there is no hearing loss over time from exposure to noise at the workplace. In addition to monitoring, a plan must be in place to help prevent long term damage to hearing. This generally will include some combination of personal protective equipment and limited exposure to high noise areas.

If you have not recently updated your hearing conservation program, or have not yet established such a program, please contact us and we will make sure your facility is up to code. If you have anything to add about the importance of a hearing conservation program, please leave a comment.

Web-Based Monitoring for Lockout Tagout

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After instituting lockout tagout procedures, it is important to have a system in place to monitor these procedures. First, you need to have a way for your employees to access the procedures to ensure compliance, and second, you need to have a way to update your procedures as your business needs change. For many, this is done in house by the safety team. For others, it is not done at all. And if you fall into either of these two categories, it might be time to look into web-based monitoring software for your lockout tagout procedures.

Web-based monitoring allows you to define a procedure library based upon our extensive library of procedures, ensuring you will have procedures which are up to code. These procedures are fully customizable and can be custom-designed to fit your company needs. After inputting all of your information, the procedures can be accessed anywhere a computer has internet connectivity through a website login and password. From there, the program is completely in your hands. You can update information as needed and it is fully scalable, meaning you can have 1 or 100 people working at once.

And best of all, as regulations change, this software will track those changes to help ensure you are up to code.

If you are still managing your lockout tagout monitoring yourself, it might be time to look into another option. Please contact us if you have any questions about how our software can help you. And if you have anything to add about monitoring lockout tagout procedures, please leave a comment.

Auditing Your Safety and Health Management System

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Safety and Health Management Systems are an integral part of any successful safety plan for a company. It is a central place to house all policies pertaining to safety, allowing quick access to these policies for review by management, safety personnel, or anyone else interested in a company’s safety practices. A Safety and Health Management System also allows easy updates to company policies when OSHA or other regulatory bodies update their regulations.

And while it is easy to create the structure of the Safety and Health Management System, actually implementing it and ensuring that all of the parts are accurate and up to date is not so easy. it is generally advised that you consult an expert when putting your Safety and Health Management System together, just to ensure you are starting off in compliance, and optimally organized.

But it is also important to properly update a Safety and Health Management System over time, and this is where many companies run into problems. Over time they expand their business or miss a regulatory change, and suddenly their Safety and Health Management System is out of compliance. And when your procedures are out of compliance, your company will be out of compliance.

It is for this reason we recommend at least annual audits of your Safety and Health Management System. These audits can be as superficial or in depth as you would like, but a second set of eyes from someone removed from the company can be an amazing resource for ensuring that your company remains up to code.

If you have any questions about implementing or maintaining a Safety and Health Management System, please contact us. And if you have anything to add about Safety and Health Management Systems, please leave a comment.

Lockout Tagout Computer Monitoring

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Setting lockout tagout procedures for your facility is hard. Maintaining your procedures over time and monitoring the accuracy of updates to your system is even harder. Each time there is an upgrade or addition to your machinery, or there is a change in personnel, there is the need to ensure the procedure library is still up to date and accurate. Further, you need to ensure that machines which have changed or been added to your company are fully lockout tagout compliant.

For many business owners, it is cheaper and more time effective to simply utilize software to track and monitor these changes. Unfortunately, most software requires routine updates to ensure accuracy to the most recently updated regulations. This, too, can create problems for many business owners, as outdated software can create a situation where a non-compliant machine is registering as compliant after policy changes.

To combat this problem, it is best to use web based software that is continually updated as needed, ensuring your procedures are checked against the most recent regulatory changes. Here at PF Safety, we have created a web based program which is fully scalable, fully customizable, and guaranteed to always be updated, that allows you to manage and track your lockout tagout procedures.

If you have any questions about your lockout tagout procedures, or would like more information on how our web based software, Factory Solutions Software, can help your business, please contact us. If you have anything to add about the challenges of monitoring lockout tagout, please leave a comment.