Monthly Archives: October 2013

Permit Entry Systems for Confined Spaces

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Confined spaces are a necessary evil for many industries. They present extremely unique challenges to employers and safety teams, and are aggressively scrutinized by the Department of Labor’s Occupational Safety and Health Administration (OSHA). OSHA created Standard 1910.146 to help employers understand the definition of, and requirements for, confined spaces.

This standard explains that a confined space is any space which meets the following 3 criteria: it is large enough and so configured that an employee can bodily enter and perform assigned work; has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and is not designed for continuous employee occupancy. But the standard also discusses permit entry systems, which are what really matter if you have a confined space.

Unfortunately, determining whether or not your confined space requires a permit entry system can be complicated. If, after reviewing the standard, you feel you might need to establish a permit entry system, it is best to have the facility audited by a professional safety consulting firm to help you determine what kind of permit entry system is required for your facility.

If you would like more information on determining whether or not a space in your facility qualifies as a confined space, or if you feel you need to establish a permit entry system, please contact us. If you have anything to add about confined spaces and the importance of a proper permit entry system, please leave a comment.

OSHA Transitioning to Safer Chemicals Toolkit

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Last week, the Occupational Safety and Health Administration (OSHA) released a toolkit to help employers and employees find safer alternatives to some of the more dangerous hazardous chemicals currently in use. OSHA’s standards regarding hazardous chemicals are woefully outdated, and many chemicals thought to be dangerous are still available and are still used, unregulated.

This toolkit is designed to help protect workers by explaining the process of eliminating those dangerous chemicals through informed substitution. The toolkit provides a step-by-step guide for this transition, and helps employers create a true and comprehensive chemical management system which goes far beyond basic OSHA standards. This form of a chemical management system provides a truly safe work environment for employees, while remaining cognizant of the bottom line of the company.

If your company uses hazardous chemicals, this toolkit is certainly worth looking at. Many of the substitutions are cost effective and efficient, and will reduce the potential of future onsite injuries. And should you be interested in establishing a proper chemical management system, but feel unprepared or unable to make such a change, it is always advisable to consult a qualified third party auditing company which specializes in OSHA standards and interpretations.

If you have any questions about the new Transitioning to Safer Chemicals Toolkit, please contact us and we will help you to understand what you need to do to create and maintain a safe work environment. Should you have anything to add about the importance of a chemical management system, please leave a comment.

Marking Pipes (ANSI/ASME A13.1)

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Twitt

Exposed pipes in a facility have the potential to create extremely hazardous situations. Because of this, many employees are nervous working around or walking under unmarked pipes in a facility. Further, in an emergency situation, it can be extremely important for emergency personnel to quickly and accurately tell what is in the exposed pipes in a facility.

For these reasons, it is important to establish a system for marking the pipes in your facility. And when establishing your system, there are really only two options. You can either create a custom system for your facility or you can utilize a current, industry accepted, system. If you decide to use the industry standard, which is usually recommended, you will want to check out ANSI/ASME A13.1. This is the most commonly accepted system, and is used almost universally.

The benefit of this system is that first responders will understand the color coding system without needing to reference your coding system. By using a system that is used as widely as the ANSI/ASME A13.1, most first responders will be trained on that system. Additionally, the actual pipe markings will be large enough for the first responders to see, since the system created by ANSI/ASME has very rigorous standards for the size, shape, and colors of each sign.

If you have any further questions about establishing a pipe marking system or about using ANSI/ASME A13.1, please contact us. If you have anything else to add about marking pipes, please leave a comment.

Lockout Tagout Procedure Monitoring

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After establishing lockout tagout procedures, many business owners and safety teams think that their jobs are done. But in reality, that is only the first half of the lockout tagout battle. Monitoring and maintaining those lockout tagout procedures is often a far more difficult task than the creation was.

Unfortunately, when we audit the facilities of new clients, it is unbelievably common for there to be absolutely no plan in place for the monitoring of lockout tagout procedures. Or, if a plan is in place, it is completely irrelevant and ineffective. So after you create your lockout tagout procedures, please ensure you put a meaningful, useful plan in place for monitoring the procedures.

When creating your plan for monitoring your lockout tagout procedures, there are two basic options: do it yourself or let someone else do it for you. For many companies, doing the lockout tagout monitoring themselves is not really possible, due to the staff in place and the associated costs. However, we also run into many companies which are unable to hire on a qualified third party safety auditor due to perceived high costs.

Fortunately, there is also a fully automated online option. Our Factory Solutions Software is fully scalable, fully customizable, and updates in real-time. It allows multiple users to log in simultaneously and is available anywhere an internet connection is available.

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

Accident Prevention Signs and Tags

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Accident prevention signs and tags are seen throughout any workplace. These signs include danger signs, caution signs, hazard signs, safety instruction signs, vehicle signs, evacuation signs, and any other workplace signs which warn employees of potential hazards. When creating these signs, it is important to make sure they are compliant with OSHA Standard 1910.145.

Standard 1910.145 was created by OSHA in an effort to make workplace signage more uniform and accessible to employees. This standard sets the requirements for the size, shape, and color of signs used in a workplace. It also covers the size of the lettering in the signs, as well as their color and design.

This standard was created with both a mind to potential evacuation situations and needs, as well as to easy access to the signs on a day to day basis. Because of the uniform nature of this standard, any first responders arriving to your facility will know exactly what the hazards are, rather than trying to guess.

Fortunately, we have an online store available for most of your sign and tag needs. We can create any sign you need, and we ensure that the signs are up to code with OSHA. We have found that, by worrying about your sings for you, you can focus on more important safety matters.

If you have any questions about the signs at your workplace, or if you need new signs, please contact us. And if you have anything to add about accident prevention tags and signs, please leave a comment.

West Fertilizer Co. Fined $118,000 by OSHA

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West, Texaswas devastated on April 17 when an explosion inside a fertilizer plant killed 15 people and injured more than 160 others. Now, 6 months later, word has been released by Sen. Barbara Boxer of Californiathat OSHA has issued 24 citations for serious safety violations which caused the explosion. And the price tag for those violations is $118,000, which is relatively small compared to the multimillion dollar fines normally associated with offenses of this magnitude, but still not a fine most companies can easily absorb.

All 24 violations were classified as serious, and 8 of them related to the stockpile of solid ammonium nitrate fertilizer which started the explosion. There were citations for inadequate ventilation in the storage facility, improper fire walls which weren’t fire resistant, improper wooden storage bins, storage piles which were too high, a floor pit which allowed melted ammonium nitrate to collect, and a lack of fire hydrants or other water supplies.

In addition, there were citations for improper emergency planning and for improper storage and handling of anhydrous ammonia.

Hopefully, this news will help prevent another tragedy such as the one seen in West, Texas. If your facility utilizes any kind of flammable or toxic substance, and you have not recently reviewed your safety plan as it relates to these items, please do so. And if you are not confident in your plans, contact a professional auditor to perform a full third party safety audit.

If you have any questions about how these violations might pertain to your business, or if you would like to schedule a third party safety audit, please contact us. If you have anything to add about the violations filed against West Fertilizer Co., please leave a comment.

The Government Shutdown and OSHA

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Everybody at this point understands that the government is shutdown. Non-essential personnel are furloughed, offices are shuttered, and some departments are not working properly. And OSHA is among the agencies hit hardest.

OSHA has furloughed 90 percent of it’s inspectors, according to a Set. 10 memo released by David Michaels, the head of OSHA. This means that, unless it is deemed a serious emergency, complaints will not be answered until after the shutdown ends. And while this might sound great for companies, as it gives them more time to fix an issue, it can mean unsafe work environments last longer, creating more complaints, more chances for a serious injury, and potentially higher fines. If you have any fears that your workplace is not 100% up to code, now is the time to have a full third party audit, to ensure you won’t have a knock on your door when the government is back up and running.

OSHA is also unable to answer inquiries from employers about interpretations of standards. So if the normal turnaround time is anywhere from one to six months, the shutdown could easily double that delay. For a company building a new complex, that delay could have a significant cost impact.

If you have any questions about how to interpret an OSHA regulation or if you would like more information on a third party safety audit, please contact us. Or, if you have anything else to add about the impact of the government shutdown on workplace safety, please leave a comment.

Establishing Procedures for Lockout Tagout

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Twitt

When attempting to establish lockout tagout procedures, it is important to be sure you keep OSHA Standard 1910.147 in mind and central to your procedures. This standard, as well as any of the many other standards which could apply when establishing lockout tagout procedures in various situations, can be very confusing and can create a number of difficulties.

To combat the potential difficulties associated with creating lockout tagout procedures, many companies either hire a professional firm which specializes in safety management or they utilize online quick reference guides. And while either option can be of benefit, it is important to analyze the needs of your company before proceeding either way, or you could waste time, money, and resources on a plan that will not fit your needs.

And what you will ultimately be analyzing is whether it makes more sense to establish your lockout tagout procedures in-house or to hire a firm to help you. There are certainly some great online tools available to help you establish your procedures, but these should never be at the heart of your plan to establish procedures, or you will end up with incomplete and dangerous procedures. Instead, you need to evaluate your personnel and their level of experience in working with lockout tagout, as well as the overall scope of the project, and what it would cost to dedicate your staff for a period of time to this task.

If those costs are lower than the cost to hire an outside firm, and if you have the right people in place, then it might make sense to do it in-house. But if you have any doubts at all about the staff you have in place, then it might be wise to seek outside help.

If you have any questions about the costs associated with hiring a firm to help you with your lockout tagout needs, please contact us. And if you have anything else to add about establishing procedures for lockout tagout, please leave a comment.

Plans for Fire Protection

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Fires can happen anywhere and at any time. They usually happen without warning and, without the proper fire protection plan in place, they can grow and build without anyone knowing until it is too late. And for this reason, OSHA created Standard 1910.155.

Standard 1910.155 sets the guidelines for fire protection equipment, including setting basic requirements for what equipment and prevention methods are required to be available. It explains what is required of some of the most commonly used fire prevention and detection equipment. This equipment includes: fire alarms, fire extinguishers, sprinkler systems, employee alarms, and smoke detectors. The standard goes into specific details for many of these items, including how to properly maintain them with a rigorous auditing schedule and how to properly label them. This equipment is very important for fire prevention and suppression, and usually is the most important equipment to ensure a safe and healthy evacuation after an incident; it is also very important for business continuity.

The standard also explains what must be done in the event of a fire. Much of this standard, at lease in reference to the steps which must be followed in the event of an actual fire, overlaps with Standard 1910.36 which covers evacuation plans. If your evacuation plan is not included with your fire protection plans, you should revisit your plans to ensure they are up to code.

If you have any questions about fire protection plans, please contact us so that we can help you through your issues. And if you have anything to add about fire protection plans, please leave a comment.

Is It Better to Outsource Lockout Tagout or Manage it In-House?

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Twitt

This question of whether it is better to outsource lockout tagout procedure creation and maintenance or if it is better to maintain it in-house, has because a somewhat recurring theme of this blog. And the reason for this is simply the frequency with which our customers ask us this question. And while every company’s needs are completely different, here are some quick tips for helping you determine which route might be best for you.

When determining whether it is better to outsource a lockout tagout project or manage it internally, there are really three major considerations: scope, timeframe, and cost. When you understand your needs in relation to these three aspects, you can really determine what the best course of action is for you.

When considering the scope, you are really determining if this is a one time need or an ongoing need, and how deep the need is. So, are you instituting a new lockout tagout program for your company, or are you adding a few new machines? Do you have a plan in place for the ongoing monitoring, or will that also be a need?

Once you determine what, exactly, the scope of your project is, the next thing to consider is the timeframe. Is this a project which needs to be completed in 10 months or 10 days? If new staff will be needed, will you have time to train them? As a general rule of thumb, the shorter the timeframe, the more likely you will need some help from a qualified consulting firm.

Finally, you need to look at the costs. Do you have an unlimited budget to add additional staff, bring in trainers, and learn to do things the right way in house? Or, if you have a qualified staff which could easily handle the new burdens, then would it make sense to spend the money on a consultant?

At the end of the day, every single instance is different. But if you need some help in determining what makes the most sense for your company, please contact us. And if you have anything to add about which option for lockout tagout is better, please leave a comment.