Monthly Archives: January 2014

OSHA Compliant Signs and Safety Signs

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Signs, safety signs, and safety visuals are the cornerstone of a good safety plan. Compliant signage which is properly maintained is both the first and last line of defense against most potential hazards in a facility. They are a constant reminder to employees of dangers and they serve as a warning of potential dangers to any persons in a hazardous area who do not normally work in that area. And when signage is not properly maintained, it can give people a false sense of security that there are no hazards in the area.

Unfortunately, keeping up with signage is more difficult than it sounds. First, you have to cross reference OSHA Standard 1910.145, which governs safety signs, with the standards associated with the potential hazard, to ensure the sign in place is adequate and properly placed. Next, you need to have a plan in place to routinely review your active signage to ensure it is not damaged and has not been removed. If the signage has been removed or damaged, it will obviously need to be replaced. Finally, you need to keep an eye on the regulations, to ensure your sign requirements do not change. Should there be a regulatory update, it could create a situation where some or all of your signs are no longer compliant.

To help you with these challenges, Premier Factory Safety has a sign store where you can customize any sign or safety visual to your required specifications. In addition, we offer facility auditing services to help ensure your current signs are still compliant.

If you have any questions about a safety sign or visual in your facility, or about signs and visuals in general, please contact us. And if you have anything to add about safety signs and safety visuals, please leave a comment.

Creating Lockout Tagout (LOTO) Procedures

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Twitt

Anyone who owns or manages a company which deals with machinery that is covered by OSHA Standard 1910.147, which is the lockout tagout standard, can tell you how difficult it is to initially create lockout tagout procedures. The standard is difficult to read, the shortcut material available is often inaccurate or vague, and any inaccuracies in the procedures can lead to serious workplace injuries or even death. For these reasons, many owners ultimately hire a professional firm to help in creating those lockout tagout procedures. The feeling for most is that the small upfront expense is worth protecting the company from OSHA, and its employees from serious harm.

Unfortunately, there are many, many occupational safety and health auditing firms which claim to have the ability to help these business owners. And we have had more than a few instances where we were brought in to fix a problem created by a competitor. So to help you avoid that potential problem in the beginning, make sure to do your due diligence and thoroughly vet the prospective company, including the auditor who will be coming to help you. Make sure the auditor can answer questions about your facility, about lockout tagout in general, and about how best to prepare for potential future changes. And if you sense any hesitation or that anything is amiss, it is probably a good idea to find someone else.

If you have any questions about creating lockout tagout procedures, or about vetting a potential lockout tagout auditing firm, please contact us. If you have anything to add about creating lockout tagout procedures, please leave a comment.

MFA Fined $91,000 by OSHA for 13 Serious Violations

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A worker was fatally injured on August 26 at an Aurora-based Milling plant in Aurora, Missouri which is owned by MFA, Inc. Following the tragedy, OSHA inspected the facility and found 13 serious violations, including several relating to the death of the employee. OSHA has proposed fines in the amount of $91,000.

“This was a terrible, preventable tragedy that underscores the importance of OSHA’s standards. Employers are required to use equipment in accordance with manufacturer’s specifications,” said Barbara Theriot, OSHA’s area director in Kansas City, Mo. “Employers are responsible for identifying hazards, providing safety precautions such as guard rails and ensuring workers follow proper procedures to prevent injury or death.”

The 13 serious violations include: failing to guard open-sided floors throughout the plant with varying fall distances up to 20 feet; inadequate footing space on industrial ladders creating fall distances up to 125 feet; failing to inspect man lifts every 30 days; failing to have guarded belts and pulleys on machinery; failing to use proper connectors, thus exposing workers to electrical conductors on motors; failing to have two exit doors; obstructed exits; unmarked and poorly lighted exit routes; and failing to have an alarm system to warn workers of fires and other emergencies.

All of these citations would have been easy to correct and could have saved an employee’s life. And the cost to fix these issues would have been virtually nothing. That is why it is important to have a qualified occupational safety and health auditing firm inspect your facility on a regular basis. A simply third party safety audit would have uncovered these problems in a matter of hours.

If you have any questions about third party safety audits, please contact us. And if you have anything to add about the importance of third party safety audits, please leave a comment.

Confined Space Permit Entry Systems and Signage

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Confined spaces pose a problem for employers in many fields. They come in all shapes and sizes, and no two confined spaces are exactly the same. Additionally, most confined spaces are associated with additional hazards, requiring additional scrutiny when creating plans for dealing with these spaces.

To help safety teams ensure their confined spaces are safely managed, OSHA created Standard 1910.146, which sets minimum standards for confined spaces and their associated permit entry systems, if required. But it is important to remember that just because you are compliant with this standard, that does not mean your confined space is fully compliant; as we mentioned earlier, there are often other standards which must be considered when creating a plan for a confined space and its associated permit entry system.

With all of this in mind, it is time to determine which sites in your facility qualify as confined spaces, and which of those require a permit entry system. To start, a confined space, according to OSHA, 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.

Determining which areas fit these three criteria is easy; determining which require a permit entry system is less easy. You can review standard 1910.146 to see what system, if any, is required for your facility. But with all of the nuances associated with confined spaces, it is often more practical to consult a professional occupational safety and health consulting firm.

If you have any questions about confined spaces and permit entry systems or their required signage, please contact us. If you have anything to add about confined space permit entry systems and their associated signage, please leave a comment.

Challenge of OSHA’s HazCom Standard Rejected in Appeals Court

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The American Tort Reform Association asked the court to review Paragraph (a)(2) of the newly revised Hazard Communication standard. This paragraph states that the new chemical labeling regulations do not preempt failure-to-warn claims filed in state courts.

Now, this ruling probably will not have much of any impact on business owners. But what will have an impact are the HazCom standard updates, which just cleared a huge hurdle now that this review has completed.

OSHA is updating its Hazard Communication standard to be in line with the chemical labeling system used by the United Nations. And many of the changes are significant enough to warrant a review of any procedures in place regarding Hazard Communication. The primary changes will revolve around the actual labels utilized in the work place and on the job site. So when reviewing your procedures, please ensure that you pay special attention to these portions of the standard.

If you are concerned with how these changes will impact your business, it might be a good time to consult an occupational health and safety management firm to review your current procedures and to guide you through the pending regulatory changes. The sooner you begin to formulate a plan and implement changes, the smoother your transition will be. And in this case, OSHA will be looking for companies which do not have a smooth transition.

If you have any questions about the regulatory changes upcoming to HazCom or about the recent legal decision, please contact us. And if you have anything to add about the recent court decision, please leave a comment.

Forever 21 Fined Over $236k by OSHA for Repeat Violations

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OSHA inspectors audited Forever 21 locations in Paramus and Manhattan in July after receiving complaints alleging violations. The results of those audits have come in, with proposed penalties to Forever 21 in the amount of $236,500. These fines were for six repeat citations and one serious citation.

The repeat citations, which are citations issued when a substantially similar violation is found at any other facilities owned by the same employer within the previous 5 years, were for: obstructed exit routes, fluorescent lights with no covers, a fire extinguisher that was not mounted and readily accessible, and stored material that was not secured against sliding or collapsing. The obstructed exit routes and fluorescent lights with no covers were citations at both facilities, while the other two were only at the Paramus location.

The serious citation, which is a citation issued when there is “substantial probability that death or serious physical harm could result and the employer knew, or should have know, of the hazard,” was issued because the Manhattan store was not kept clean and orderly.

This is a prime example of why companies need to have all of their facilities audited by professional third party occupational health and safety experts. Many employers do not think of retail spaces as a place where OSHA will come knocking to audit, but it is important to remember that OSHA will take complaints anywhere you have employees working.

If you have any questions about third party safety and health auditing, please contact us. And if you have anything to add about the importance of third party safety audits, please leave a comment.

Finding The Right Firm to Help With Lockout Tagout Procedures

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We are often called to help companies update existing or establish new lockout tagout procedures after they have had an issue with their existing procedures. Many clients have already hired a third party to create their initial procedures, but the procedures were either created incorrectly or were not created in such a way that they could account for changes. In these situations it can often be far more difficult to fix the incorrect procedures than it would have been to simply establish new procedures the correct way.

For these reasons, we always recommend credentialing the firm which will help you to establish your lockout tagout procedures. There are a number of ways to do this, including checking what certifications (if any) the firm has, finding out about the work history of the firm and its employees, and asking for references. But at the very least, it is important to question the person who will be auditing your facility and developing your procedures about lockout tagout in general and your facility specifically, focusing on how you will be able to update your procedures in the future, should your needs or regulations change. It is amazing how little unqualified specialists know, and you can usually sniff that out.

If you have any questions about your existing lockout tagout procedures, or if you are interested in establishing new procedures, please contact us and we can explain how our process ensures compliance for you now and in the future. If you have anything to add about the importance of establishing lockout tagout procedures correctly the first time, please leave a comment.

Auditing Lockout Tagout (LOTO) Procedures

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After establishing Lockout Tagout procedures, it is important to maintain them. A key component of maintaining lockout tagout procedures is to routinely audit them. These audits should include a full review of the current lockout tagout procedures, a review of any changes since the last review, and a review of the machines covered in the procedures. Additionally, it is important to review the training plan, how the procedures are made available to employees, and how management is held accountable for ensuring lockout tagout compliance.
When reviewing the lockout tagout procedures, it is important to be mindful both of changes to the facility and personnel, as well as changes to the OSHA standards. Both of these components are vital, as you will not be in compliance if either piece changes and is not accounted for in the procedures.
When reviewing the changes, it is important to understand the “why” behind the change as much as understanding the actual change. Many clients will update their procedures correctly, meaning the changes are in compliance with OSHA standards, but the changes are not correct for the need, so the company is still out of compliance.
And finally, the training and availability are as important as the procedures themselves. If an effective plan is not in place for employees to learn the procedures, then they will not be properly followed, and the hazards will still be present.
If you have not recently had your lockout tagout procedures audited, please contact us so that we can help you determine if you are in need of a review. And if you have anything to add about the importance of auditing lockout tagout procedures, please leave a comment.

Arc Flash and Shock Monitoring

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Establishing a competent and compliant arc flash and shock hazard plan can be extremely difficult. Every machine in a facility needs to be tested, the entire circuit needs to be tested, and the results need to be compared against the very difficult to understand NFPA 70E. And there is no real OSHA standard to compare NFPA 70E to, so the only point of reference is the document itself or third party documents, which may or may not be credible.
But after you overcome the challenge of establishing an arc flash and shock hazard plan, there is still a constant need to monitor the plan. As machinery, employees, or regulations change, so too do your plans need to change. And each time a change is made, the entire plan needs to be reworked to ensure nothing else is out of compliance from the changes.
To help avoid difficulties with changes, many companies hire a professional safety and health management company to monitor and update their plans. But when hiring a company, you need to ensure you are hiring a qualified company with auditors who are properly prepared to help your business transition into the future, no matter what changes may lay ahead. In order to properly vet auditors, make sure to not only ask them questions about what to do now, but also how to handle potential future changes. If they have difficulty in articulating how to compensate for potential future changes, it might be a good idea to look elsewhere; you do not want someone reviewing your arc flash and hazard plan who cannot manage it indefinitely.
If you have any questions about arc flash and shock monitoring, please contact us. And if you have anything to add about the importance of arc flash and shock monitoring, please leave a comment.