Monthly Archives: July 2013

Means of Egress

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Twitt

OSHA takes evacuation very seriously. In the event of a true emergency, the only thing which may be able to protect life and prevent serious injury is a well designed, clearly labeled,  and properly maintained evacuation route. And as the standards were being formed, OSHA ultimately created two separate standards for evacuation – 1910.36, which covers the construction of the exits and routes, and 1910.37, which describes how the routes need to be maintained, what safeguards need to be in place, and how to handle changes to the original evacuation route.

Standard 1910.36 can be seen as the planning and building standard for means of egress. This standard dictates how to create an evacuation plan, how many exits must be available, and how many possible routes must be available from any given location in your facility. Further, it sets regulations on how these paths must be built, and how the exits must be constructed. This includes the size of the openings, the types of openings, the materials used, and the accessibility.

Standard 1910.37 can be seen as the post-construction standard for evacuation routes. Once you have created your evacuation plan and constructed all of your paths and exits to code, 1910.37 will guide you on how to maintain these routes. This includes the safety features required for various pathways and exits, the lighting which is necessary, the signage, and the fact that the routes and exits must be left unobstructed.

If you have not recently reviewed your evacuation route, it is important to do so. And if you have any questions about your specific situation, please contact us so that we can guide you through these standards and explain how they pertain to your unique facility. If you have anything else to say about means of egress, please leave a comment.

Lockout Tagout: Outsource It or Manage it In-House?

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Twitt

Many prospective customers wonder if they are better off hiring an outside consulting firm to handle their lockout tagout needs, or if it makes more sense to manage their lockout tagout needs in house. And while this is a smart question to ask, it is important to ask yourself and your team relevant follow up questions which will help uncover the company’s ability to handle lockout tagout internally.

It is imperative that you look at your employees when making this decision. If, for instance, you have a lockout tagout expert on staff who can be dedicated to the project, at least in the short term while building a lockout tagout procedure, then your company is in a better situation than a company which will be relying upon a safety team that is new to lockout tagout. Further, you need to consider what tasks the individuals who will be assigned to the lockout tagout project are currently working on. If they are stretched thin as it is, where will the extra time needed for lockout tagout come from? If it will create an environment where the staff is not able to effectively review the lockout tagout procedures, then a serious problem could result.

Another important aspect of a lockout tagout project is the required timeframe. If you need this project completed in 2 days, you will be far less capable of properly training a staff as you would if you had 3 months to completion. Additionally, you need to determine if the lockout tagout monitoring is a part of this project, and if so how that will be managed by your staff.

Once you have asked yourself these questions, you are in a better position to make your decision. A simple cost analysis will help you decide which option is best financially. Armed with that information, you can then decide if it will be easier to hire a safety consulting firm or to manage your needs in-house.

If you have any questions about the benefits of outsourcing your lockout tagout needs, please contact us. And if you have anything else to add about the pros and cons of outsourcing, please leave a comment.

Arc Flash and Shock Hazards

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An arc flash event will injure employees in several ways. It will burn them, it will peg them with nearby objects, it will hit them with blunt force from the blast pressure, and it will damage their ears with a sound blast which can reach upwards of 140dB. An arc flash event will also likely start a fire and create deadly heat, reaching temperatures as high as 35,000 degrees Fahrenheit. For these reasons, it is imperative that you assess your facility for arc flash danger zones and do everything you can to limit the risk of an arc flash event.

The regulations surrounding arc flash are set in NFPA 70E, which OSHA regulators will follow should your facility be audited. Unfortunately, this regulation is difficult to understand and sets many guidelines which can be difficult to effectively monitor. Further complicating the matter, IEEE 1584 is used as an alternative by many companies, as it is more user friendly, however it is hardly a complete guideline. Following the guidelines set forth in IEEE1584 should only be a starting point, not an ending point, for creating an effective arch flash and shock safety program.

At the core of your arc flash and shock safety plan must be employee training, proper labels, de-energizing circuits, and personal protective equipment. In the event your employees will be working with energized circuits, it is imperative to have a safety program in place and to properly train the employees how to follow the safety program. This program should include insulated tools, personal protective equipment, and a system which only allows qualified individuals access to the energized circuits.

If you have any questions about your arc flash and shock safety plan, please contact us. And if you have any other information about arc flash and shock hazards, please leave a comment.

Fire Protection Plans

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Fire poses a threat to companies in all industries. If not properly contained, they can severely injure or kill employees, and can bring business to a screeching halt. Fortunately, there are many things a safety team can do to greatly reduce the risk of a widespread fire in a place of business. OSHA Standard 1910.155 states the guidelines which any safety team should follow in relation to fire protection and prevention. Following these guidelines will reduce the chances of a fire, help prevent the spread of a fire in potentially dangerous situations, and will put into place procedures to protect employees should a fire grow beyond easily suppressible levels.

First and foremost, it is important to have federally approved fire protection equipment in place. Approved equipment is equipment which has been tested by a third party and deemed to be compliant with the National Fire Protection Association Fire Code, or must be custom made and have test data available to inspectors.

This standard also discusses the basic requirements for some of the most common, and most important, preventative equipment which is necessary in any workplace. This include things like sprinkler systems, fire extinguishers, fire alarms, and employee alarms. It discusses in detail the various sprinkler systems and fire extinguishers which a company might utilize, and how to properly audit and label them.

Finally, this standard discusses what must be done in the event of a fire. This includes what systems must be available, what escape mechanisms must be in place, and also ties in with all applicable evacuation plan requirements.

If you have not recently reviewed your fire protection plans, or are afraid your plan is not up to code, please contact us so that we can help. And if you have anything to add about fire protection, please leave a comment.

Confined Space Permit Entry System

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Any facility with a confined space must ensure a permit entry system is not required before allowing open access of the space to employees. The requirements surrounding the need for a permit entry system can be found in OSHA Standard 1910.146. This standard regulates confined spaces in general, but also sets specific requirements as to when a permit entry system is required and how to properly monitor and maintain the permit entry system.

The most important part of a confined space permit entry system is the written procedures. These procedures state who may access the confined space, when and under what circumstances those individuals may enter the confined spaces, and how those people may enter the confined space. These procedures must have printed instructions available at every entrance to the confined space, and the space itself must be properly labeled with the correct signage.

In addition, if there are any additional requirements, they must be listed in the procedures. This can include the need for an attendant. If an attendant is required as per the standard, then it must be clear who the attendant is, when the attendant is there, how the attendant will keep track of individuals entering and exiting the space, and how the attendant can contact those inside the confined space. Similarly, personal protective equipment is often an important part of confined space procedures. If any equipment needs to be worn by those accessing the space, it is important that equipment is readily available and clearly marked on the instruction cards.

Should you have any questions about a confined space permit entry system at your work place, please contact us so that we can help you ensure you are up to code. If you have anything to add about confined space permit entry systems, please leave a comment.

Lockout Tagout Software

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Twitt

Time and again, we find that creating and monitoring lockout tagout procedures is the most difficult task for safety teams in facilities we audit. These procedures involve a very detailed understanding of a complicated OSHA standard, and there is a lot of misinformation out there about what is, and is not, acceptable. And once an effective procedure is created and put in place, many safety teams do not have the ability to effectively monitor and update these procedures.

OSHA Standard 1910.147 governs the creation and monitoring of lockout tagout procedures. This standard gives employers fits, and many companies wind up over paying outside agencies to create, implement, and monitor their lockout tagout procedures, without ever teaching their safety teams what these agencies are doing, or properly monitoring the activities of the outside agency. They then have to hope the company they have hired is acting appropriately, and that their facility is up to code.

Recently, we released Factory Solutions, a powerful web based tool for managing lockout tagout procedures. This program allows users to create, update, and monitor lockout tagout procedures based upon the specific needs of their business. It is fully customizable, fully scalable, and can be accessed anywhere internet is available. This software ensures your company is always up to code, by reviewing your procedures and notifying you if anything is not in compliance. And should anything change in the regulations, the software will recertify that you are still in compliance.

Should there be a compliance issue, the software notifies the user. In this way, you and your team are always in control, helping you to rest assured that your facility is in compliance. With this software, you have the benefit of an experienced firm behind you, the accuracy of the technology, and the ability to teach your safety team what proper lockout tagout procedures should look like and how to effectively manage them.

If you have any questions about our Factory Solutions software, or about lockout tagout in general, please contact us. And if you have anything to add about the effectiveness of Factory Solutions, please leave a comment.

Most Commonly Cited OSHA Violations Part 3

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In the first part of this series, we discussed the first 4 most commonly cited OSHA violations. In the second part, we discussed the next 3. Today, we will be discussing the three most commonly cited OSHA violation in 2012.

3. Scaffolding, General Requirements, Construction (29 CFR 1926.451)

Scaffolds are an important part of any construction project. They add extra walking and working surfaces to incomplete areas and allow access to otherwise inaccessible area. However, these scaffolds are regulated by this standard, and often are not up to code due to their short-term nature. If your company utilized scaffolds, make sure they are up to code, specifically focusing on access, construction, and their ability to handle the weight of the workers.

2. Hazard Communication Standard, General Industry (29 CFR 1910.1200)

Hazardous materials are a serious threat to employee safety. This standard regulates the signage and other communication surrounding these materials. Make sure all materials are properly labeled. This means that the labels must be accurate and that the labels themselves must also be up to code. Also be sure there is a written policy in place for employees to refer back to.

1. Fall Protection, Construction (29 CFR 1926.501)

This is one of those violations which hover around this number one spot year after year. This standard regulates what protections and devices are in place for workers working at any height of four feet or higher. This height requirement often trips up companies, as they disregard the risks associated with perceived “small falls.” Holes are also a common source of violation, as there are multiple potential standards which holes can fall under. To avoid problems, be sure to have a written plan in place for any employees working at a height over 4 feet, and make sure to communicate this plan to all employees.

And that is it. Those are your top 10 most commonly cited OSHA violations of 2012. If you have any questions about the violations listed here, please contact us. If you have anything to add about any of these standards, please leave a comment.

Most Commonly Cited OSHA Violations Part 2

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In our last post, we covered the first 4 most commonly cited OSHA violations of 2012, as per their list. Today, we are going to cover the next 3 most commonly cited standards.

6. Powered Industrial Trucks, General Industry (29 CFR 1910.178)

If you are in an industry which uses these trucks, make sure any employee authorized to operate them is properly trained. This standard focuses heavily on training and refreshers for operators. It also focuses on the vehicles themselves; make sure your trucks are up to code, especially after repairs.

5. Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147)

This standard makes even the most seasoned safety personnel cringe. It is complicated, time consuming, difficult to monitor, and extremely dangerous. OSHA comes down hard on lockout/tagout violators, serving up hefty fines for noncompliance. If your business is regulated by this standard, you need to be sure your procedures are within guidelines, your safety team understands them, and you are adequately monitoring changes. Employee training is also of crucial importance, because if employees do not understand the meaning of the locks and tags, they will potentially endanger themselves and coworkers.

4. Respiratory Protection, General Industry (29 CFR 1910.134)

Dust masks, respirators, self contained breathing apparatus (SCBA), and other such devices are all covered by this standard. It sets guidelines regarding fit testing, air quality, exposure limits, testing, and employee training. It also details what is required to be included in a written procedure. Also remember, each device used has its own set of guidelines which must be followed; if you are following the guidelines for dust masks that does not mean your SCBA’s are up to code.

In the third and final post in this series on the most commonly cited OSHA violations, we will be discussing the three most common violations. If you have any questions about the violations listed here, please contact us. If you have anything to add about any of these standards, please leave a comment.

Most Commonly Cited OSHA Violations

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Twitt

Every year, OSHA releases a list of the top 10 most frequently cited standards. This list is important to review and understand, as it will point to trouble areas others are having and can tip you off to what OSHA is focusing on. When there are major changes to a standard, it is also common to see that standard show up on this list. This year, we are going to briefly discuss each of these standards.

10. Electrical Systems Design, General Requirements, General Industry (29 CFR 1910.303)

This standard has to do with the design of electrical systems, specifically focusing on what measures are in place to prevent electrocution and electric shock. This standard is so often cited simply because it pertains just about every business.

9. Machines, General Requirements, General Industry (29 CFR 1910.212)

This standard pertains to the guarding in place for machinery in your facility. Every machine needs to be properly guarded as per the requirements in this standard; pay particular attention to securing fixed machinery and properly covering blades.

8. Ladders, Construction (29 CFR 1926.1053)

Ladder accidents are on the rise in the United States. Though this standard is often considered complicated, most of the requirements are easy to follow once understood. Eight percent of all workplace deaths are attributed to ladder accidents, so it is important to brush up on this standard.

7. Electrical, Wiring Methods, Components and Equipment, General Industry (29 CFR 1910.305)

As technology advances, so to does the circuitry used to run machinery. But ultimately, all wiring systems require proper labeling, grounding, personal protective equipment, and monitoring. All devices also need to be complete and created up to code. This standard covers all of these topics and more.

In our next post, we will discuss standards 6-4 on the list of most commonly cited OSHA violations. If you have any questions about the violations listed here, please contact us. If you have anything to add to our brief discussion of these standards, please leave a comment.

Why Preventative Maintenance is Important to Your Safety Plan

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Preventative maintenance is, perhaps, the most overlooked aspect of a company safety plan. There are no specific OSHA standards covering preventative maintenance, and it doesn’t “feel” like a safety issue. But time and time again, organizations which routinely maintenance their machinery as per the manufacturer’s guidelines are better prepared for an audit, and have fewer potential citations.

This is because the machinery in a facility where the staff is adhering to proper preventative maintenance is less likely to have a dangerous fault. There are two reasons for this. First, the machinery is being properly examined on a routine basis, so if there is a fault that does not interfere with the usability of the machine, it will be spotted. In a facility which does not maintain the machinery, that fault might go unnoticed. The second reason is that these maintenance tasks help to keep the machines, and their safety procedures, working properly. This means that these facilities are less likely to experience a malfunctioning safety device, and should a safety device stop working, it will be found in a timely manner.

So with all of this in mind, it is pretty obvious that properly tracking and maintaining machinery is an important task. But many business owners feel that this task is too cumbersome, and that it is easier to take a chance on the equipment. But in reality, preventative maintenance is extremely easy to monitor and track. All that is required is to determine what the preventative maintenance requirements are, and to then have a preventative maintenance placard drawn up and affixed to the devices.

If you need some help in establishing your preventative maintenance plan, or would like some placards created, please contact us. And if you have anything to add about the importance of preventative maintenance, please leave a comment.