Lockout Procedures

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Evaluating Your Lockout Tagout Procedures

It is critically important to constantly evaluate all of your occupational safety and health policies and procedures. At least annually, you want to audit your facility for new hazards and ensure your existing hazards are well documented and accounted for. Finally, you want to ensure nothing changed in the way of OSHA regulations and standards. But nowhere in your facility is this more important than your lockout tagout procedures.

Your lockout tagout procedures will save lives, will be scrutinized if you are ever audited by OSHA, and are difficult to properly maintain. Personnel changes, machine updates, system buildouts, changes in workflow or process, and regulatory changes are just a few of the potential issues which will arise year over year requiring tweaking, or complete rewriting, of your policies. Unfortunately, most companies hire third party lockout tagout specialty firms to handle the creation of their lockout tagout procedures, leaving them in a situation where they cannot self-evaluate the procedures.

And while we recommend a full third party audit of all things occupational safety and health, not just lockout tagout related, many companies do not have the resources or the desire for such a service. And even those which have a routine auditing schedule run the risk of issues arising between audits.

For this reason, we created our Factory Solutions Software. It is a service which allows you to craft your lockout tagout procedures with the backing of a leader in the lockout tagout arena while remaining in control of the crafting and monitoring of said procedures. It is fully customizable, fully scalable, monitors for system or regulatory updates, and is accessible from anywhere an internet connection is available. It gives you the power to evaluate and monitor your lockout tagout procedures in real time, ensuring you are always compliant.

If you have any questions about our Factory Solutions Software, please contact us and we will be happy to explain how it will benefit your company. If you have anything to add about the importance of routine lockout tagout procedure evaluation, please leave a comment.

OSHA Proposes $110,400 in Fines for Gershenson Construction

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The U.S. Department of Labor’s Occupational Safety and Health Administration cited Gershenson Construction company for 11 safety violations. These violations are comprised of 1 willful and 10 serious violations, and are from hazards relating to trench cave-in and a lack of protection for workers from struck-by injuries. These citations come with $110,400 in proposed penalties.

“Failing to protect workers from struck-by hazards and allowing employees to work in a trench without protective systems is inexcusable and will not be tolerated,” said Larry Davidson, OSHA’s acting area director in St. Louis. “Being struck-by vehicles and other objects is a leading cause of construction-related injuries and deaths. Gershenson Construction has a responsibility to protect workers from known hazards in the construction industry.”

The willful violation was issued for failing to ensure workers were protected from cave-in hazards while working in a trench that exceeded a depth of 5 feet. The ten serious violations were issued for exposing workers to the hazards of being struck-by a partially suspended load; lack of adequate and frequent inspections of the work site for hazards; inadequate training of employees; lack of head protection; use of damaged rigging equipment; lack of permanently affixed legible identification markings on rigging equipment; and allowing an excavator to operate within 10 feet of energized, overhead power lines.

If you are in the construction industry and are not sure your procedures relating to struck-by and cave-in hazards are up-to-code, it might be time to have your health and safety procedures properly audited by a qualified third party occupational safety and health auditing firm. It could mean the difference between a safe work environment for your employees and a potentially deadly one.

If you have any questions about third party safety audits, please contact us. If you have anything to add about this investigation or the need for third party safety audits, please leave a comment.

Fire Protection and Prevention

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A fire is one of the deadliest disasters that can befall a facility. Should a fire strike, it is important that a strong evacuation plan is in place to protect lives, but even a small error in judgment on the part of an employee in a fire situation can lead to death. In addition, fires can devastate a business, destroying the facility, equipment, and goods which support it. For this reason, it is important to have a solid plan in place relating to fire protection and prevention; it can save lives and allow for business continuity.

When developing a plan, it is important to refer to OSHA Standard 1910.155, which covers the basic requirements to help prevent and suppress fires. It discusses what basic prevention and detection devices and methods are available and how to properly use them in your facility. This includes everything from fire alarms and smoke detectors to fire extinguishers and sprinkler systems. The detection equipment is crucial to giving employees adequate time to evacuate, and the suppression equipment can keep evacuation routes clear.

This equipment will save lives, but it will also help maintain your business. Should an alarm properly notify a fire department or your internal fire brigade of a fire in the early stages, it is infinitely easier to suppress than if the fire has already taken hold of half of the facility. Similarly, sprinklers and fire extinguishers can help stop fires from growing, meaning the facility, and everything inside, is protected.

If your fire protection and prevention plans were not created with Standard 1910.155 in mind, or if you fear they are no longer adequate for your facility, please contact us and we will help you update your procedures. If you have anything to add about fire protection and prevention policies, please leave a comment.

Should I Outsource my Lockout Tagout Procedures?

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Many company owners handle lockout tagout procedures in house. They create their

plans themselves, monitor them, update them, and stay abreast of regulatory changes.

They assign this as an ancillary function of the safety or operations team, and expect that

it will be handled properly, without giving much thought to it. Unfortunately, lockout

tagout is not like the rest of the occupational safety and health industry; the regulations

governing it (Standard 1910.147) are extremely complicated, every facility needs

very specific procedures in place, and even just a change in personnel can require new

procedures be written.

Unfortunately, the other option is to hire an unnecessarily expensive third party to handle

the lockout tagout procedures, from creation to maintenance to updating. And you want

to try to take over the responsibilities at some point, it is usually almost impossible as the

procedures have become so complex and firm specific.

But now, there is another option. With our Factory Solutions Software, you get the

security of a professional lockout tagout auditing firm with the comfort of knowing that

you are in control of the procedure creation, maintenance, and monitoring. And since this

software is available anywhere an internet connection is available, it means that updating

lockout tagout procedures have never been more convenient. We help you create your

procedures, we monitor them for regulatory changes, and we help you amend your

procedures should something change at your facility. It is truly the best of both worlds.

If you have any questions about our Factory Solutions Software, please contact us for

more information. If you have anything to add about whether it is better to outsource or

maintain lockout tagout procedures in-house, please leave a comment.

Policies for Personal Protective Equipment

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It is not enough to simply make personal protective equipment available to your staff, you need to have very clear and concise policies surrounding this equipment to ensure it is in good, working order; is properly used; and is properly maintained. Without these policies and procedures in place, your personal protective equipment will potentially be less effective, meaning your employees are exposed to potential hazards, and your company will be exposed to OSHA violations in the event of an audit.

Personal protective equipment protects employees in the most crucial ways. It is the last line of defense for employees, should other safety equipment fail, and it is the only defense for employees in many situations. And since personal protective equipment is on your employees’ bodies, it means that the hazards pose a real and actual threat to your staff. Worn out gloves that have holes will allow employees to burn themselves; damaged masks can blur vision or allow hazards to permeate them. And in situations like these, there is nothing else to protect the employee.

But how do you know what to put in the policies? Well, you can start with OSHA Standard 1910.132. This standard regulates all things personal protective equipment. It regulates how to store, don, doff, and use equipment. It also explains in which situations the equipment is required and in which it is not. It even explains when the equipment is the responsibility of the employer to provide and when the equipment is the responsibility of the employee to purchase. With all of this in mind, you then need to consider your worksite and determine where personal protective equipment is required.

If you have any questions about establishing policies for personal protective equipment. please contact us and we can help you establish your policies. If you have anything to add about establishing policies for personal protective equipment, please leave a comment.

Auditing Lockout Tagout Procedures

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Creating lockout tagout procedures is never an easy task; it can be difficult to understand OSHA Standard 1910.147, confusing to maintain the procedures, and time consuming to update lockout tagout procedures. But something you can do to save some time and help protect your employees is to create an auditing schedule for your lockout tagout procedures. The auditing can be done in house or with the help of a qualified third party lockout tagout auditing firm, but it should always include certain, basic things.

For starters, the audit should review current OSHA policy to ensure nothing has changed since the last review. It is likely that you will be out of compliance is the regulations changed, and is the easiest way to find yourself facing a hefty fine from OSHA. The audit should also review what changes have happened within your company since the last audit. If any machinery or relevant personnel have changed, you will want to see what, if any, impact these changes have on your lockout tagout procedures. Finally, you want to inspect your placards and other associated visuals. If they are damaged, worn, or out of date, they need to be replaced.

But based upon your specific company needs, there can be many other things required during the audit, as well. For this reason, many companies hire a third party to maintain their lockout tagout procedures. And while this helps to ensure the company remains in compliance, it can also become quite expensive, and takes the company out of control of their own procedures.

For this reason, we created our Factory Solutions Software. It is an online program which tracks and monitors your lockout tagout procedures. It is fully customizable, fully scalable, and can be updated anywhere internet is available. It will notify you if there is a problem, and will help you in updating your procedures. So it keeps you in control, but gives you the peace of mind knowing your procedures are watched by a qualified third party lockout tagout auditing firm. It also serves as constant, real-time auditing, instead of moment-in-time auditing you get with a physical audit. When combined with physical, on-site third party safety audits, Factory Solutions Software helps to create the safest work environment possible for your employees.

If you have any questions about third party safety audits or our Factory Solutions Software, please contact us. And if you have anything to add about auditing lockout tagout procedures, please leave a comment.

OSHA Proposes $160,280 in fines for American Made Tires

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The U.S. Department of Labor’s Occupational Safety and Health Administration cited American Made Tires in July of 2013 for 12 hazards at their Elmira Heights, NY facility in response to an inspection earlier that year. In May, OSHA came back to do a follow up inspection and found that the company failed to correct these hazards. As a result of this inaction, OSHA has proposed an additional $160,280 in fines to the company.

“The company’s inaction exposed employees to ongoing hazards of fire, falls, chemicals and to being caught in or crushed by unguarded or unexpectedly activated machinery,” said Christopher Adams, OSHA’s area director in Syracuse. “The sizable penalties proposed reflect the severity of these conditions and the employer’s failure to follow through on its obligation and commitment to correct hazards that never should have existed.”

As you can see, OSHA does not go easy on repeat offenders. If your company has recently been through an OSHA audit, it is imperative that you correct the issues which OSHA uncovered, even if you do not agree with their assessment. Otherwise, when they come back, they will hit you with heavy fines and penalties. Instead, it is well worth consulting a third party occupational safety and health auditing firm that can perform a full third party review to help you determine the best strategy to correct the findings.

If you have any questions about OSHA follow up audits and how to prepare for them, please contact us and we can help you through the process. If you have anything to add about OSHA follow up audits or about this case, please leave a comment.

OSHA Proposes $217,000 in Fines for Dollar Tree

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The US Department of Labor’s Occupational Safety and Health Administration proposed $217,000 in fines for Dollar Tree Stores, Inc., following an inspection performed at a location in Missoula in November of 2013. OSHA cited Dollar Tree with four violations, which were comprised of three willful and one repeat violation. These fines come on the heals of three other citations in April, which carried penalties of $143,000.

“This employer’s extensive history of ignoring basic safety standards establishes a clear pattern of intentional and complete disregard for employee safety,” said Jeff Funke, OSHA’s area director in Billings. “Employers have an obligation to keep their workers safe, and Dollar Tree keeps failing to do that.”

The history of citations for Dollar Tree comes from inspections held at different stores all across the country, showing that retailers need to be cognizant of conditions and standards at every location. If you have multiple locations, they can, and will, be inspected by OSHA, and if they are not all following proper procedures, your company can, and will, be heavily fined.

If you have recently been through an inspection at one of your retail locations, it is important that you have all of your facilities audited by a qualified third party, and that you review the entirety of your health and safety procedures, to ensure you will not be dinged in a follow up inspection.

 

If you have any questions about how retail inspections work, or if you need help updating your procedures, please contact us and we will help you. If you have anything to add about the importance of maintaining all retail stores under your company’s ownership, please leave a comment.

 

Fire Protection and Prevention

Posted on by
Twitt

A fire is one of the deadliest disasters that can befall a facility. Should a fire strike, it is important that a strong evacuation plan is in place to protect lives, but even a small error in judgment on the part of an employee in a fire situation can lead to death. In addition, fires can devastate a business, destroying the facility, equipment, and goods which support it. For this reason, it is important to have a solid plan in place relating to fire protection and prevention; it can save lives and allow for business continuity.

When developing a plan, it is important to refer to OSHA Standard 1910.155, which covers the basic requirements to help prevent and suppress fires. It discusses what basic prevention and detection devices and methods are available and how to properly use them in your facility. This includes everything from fire alarms and smoke detectors to fire extinguishers and sprinkler systems. The detection equipment is crucial to giving employees adequate time to evacuate, and the suppression equipment can keep evacuation routes clear.

This equipment will save lives, but it will also help maintain your business. Should an alarm properly notify a fire department or your internal fire brigade of a fire in the early stages, it is infinitely easier to suppress than if the fire has already taken hold of half of the facility. Similarly, sprinklers and fire extinguishers can help stop fires from growing, meaning the facility, and everything inside, is protected.

If your fire protection and prevention plans were not created with Standard 1910.155 in mind, or if you fear they are no longer adequate for your facility, please contact us and we will help you update your procedures. If you have anything to add about fire protection and prevention policies, please leave a comment.

Permit Entry System for Confined Spaces

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Confined spaces are a necessary part of many facilities. These spaces, unfortunately, have the potential to cause serious harm to employees, and are made more dangerous with the presence of other common hazards. To help prevent employee injury, OSHA created Standard 1910.146, which governs confined spaces and establishes the parameters for permit entry systems.

Once a space has been declared a confined space, meaning it is a space large enough and so configured that it is possible for a person to bodily enter and perform work, has limited or restricted means for entry and exit, and is not designed for continuous employee occupancy, an employer needs to determine if it is a permit-required confined space.

Permit-required confined spaces are spaces which contain or have the potential to contain a hazardous atmosphere, contain a material that has the potential for engulfing an entrant, has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section, or contains any other recognized serious safety hazard.If a confined space has any of these additional hazards, a system must be set up to protect the employees; this is done by either creating alternate entry procedures or creating a full permit entry system. Alternate entry procedures are allowed if the only hazard present is atmospheric in nature and if the employer can demonstrate that continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry. If forced air will not rectify the situation, then a full permit entry system is required.

These systems document who may or may not enter the space, when these people may or may not enter the space, how these individuals will be monitored, who will be responsible for monitoring entry into the space, and what safety equipment is required before entry. The space must then be routinely audited to ensure no additional hazards have developed and to ensure that all safety equipment is working effectively.

So if you own a facility which has confined spaces and you have not recently reviewed your permit entry system, it might be time to do so. If you have any questions through the process, please contact us so we can help you through the process. And if you have anything to add about the importance of permit entry systems for confined spaces, please leave a comment.