HOUSTON, TEXAS, June 14, 2017 – Total Safety, a leading global provider of integrated industrial safety services, solutions, and equipment, was recently awarded the 2016 Contractor Meritorious Safety Performance Award in 16 facilities throughout the US by the American Fuels and Petrochemical Manufacturers Association (AFPM). The awards were formally presented during the AFPM National Conference that took place May 17-18, 2017 in New Orleans.
The AFPM award recognizes contractor companies who consistently meet and exceed safety standard excellence in the U.S. refining and petrochemical industry. Criteria for award selection includes contractors that work a minimum of 20,000 hours per year at a regular member facility and achieve a total recordable incidence rate of 0.6 or less with no workplace related fatalities.
In the last five years, Total Safety has received 78 AFPM Safety Performance Awards.
“We are honored to receive these 16 Safety Performance Awards from the AFPM,” said Paul Tyree, Chief Operating Officer for Total Safety. “Our safety performance and record is of the utmost importance to our company, employees, and the customers we are fortunate to serve. Keeping others safe is intrinsic to our culture and inherent to our mission: ‘…to ensure the safe Wellbeing of Workers Worldwide (W3)’. It’s what motivates and drives our employees every day, and I couldn’t be more proud of this achievement.”
Customer sites where Total Safety’s performance was recognized for the 2016 AFPM Safety Performance Award include:
Baton Rouge Refinery of ExxonMobil Refining & Supply
Bayport Choate Plant of LyondellBasell Industries
Baytown Refinery of ExxonMobil Refining & Supply
Beaumont Refinery of ExxonMobil Refining & Supply
Chalmette Refinery of PBF Energy Inc.
Channelview Chemical Complex of LyondellBasell Industries
Clear Lake Plant of Celanese Ltd.
Corpus Christi Complex of LyondellBasell Industries
Houston Refinery of Houston Refining LP
Morris Complex of LyondellBasell Industries
Port Arthur Refinery of Valero Refining Company
Sinclair Wyoming Refinery of Sinclair Oil Corporation
Sweeny Complex of Phillips 66
Valero Ardmore Refinery of Valero Refining Company
Valero Memphis Refinery of Valero Refining Company
Valero Refining – New Orleans, LLC, Valero St. Charles Refinery of Valero Refining Company
Fall protection is a common concern for a wide variety of businesses, from contractors to manufacturers and distributors. Employees regularly need to work at potentially dangerous heights to deal with tasks ranging from equipment assembly to facility maintenance. Having an effective fall protection plan is critical, especially considering how common these incidents are.
The Occupational Safety and Health Administration (OSHA) ranked violations related to fall protection the most common infraction seen by its inspectors in both 2015 and 2016. In the longer term, issues with fall prevention have regularly ranked on OSHA’s top 10 list for many years. The high incidence of accidents related to a lack of adequate fall protection means businesses need to emphasize this aspect of their overall safety plan.
Improving fall protection efforts
“Companies have to regularly evaluate their fall protection efforts.”
As part of the regular development of a safety plan, businesses survey new facilities and take a variety of potential hazards into consideration. This includes fall protection, and the construction or move-in phase offers an opportunity to minimize the work employees do at unsafe heights – defined as four feet above ground level for general industry – as well as implement effective fall arrest systems.
Companies can’t stop there, however. They also have to regularly assess the facility and the condition of any measures used to protect employees from falls, like toe boards and handrails. Additionally, assessing any new additions or changes to previous workflows should be a priority. A minor change to the way an employee completes a task could be significantly more efficient overall but also increase the risk of a fall, something that needs to be addressed with the appropriate personal protective equipment or more permanent alterations to the environment.
Inspections also need to address fixed hazards and the resources used to guard employees from harm. Holes large enough for employees to fall into, for example, require a railing and toeboard or floor hole cover. Hazards below the four-foot mark that pose a risk related to a fall – where tripping would bring a worker into contact with dangerous machinery or substances – needs to have fall protection in place as well.
Employee training is another critical consideration, and one that also has to be regularly revisited. The need for comprehensive training, which stretches from describing the hazards of falls and how improper use of fall protection systems can increase the risk of employees suffering an injury to proper equipment inspection and maintenance, is ongoing. New employees need to be trained before they take on any tasks at dangerous heights, and refreshers for existing employees can go a long way toward making sure they stay as safe as possible.
Fall protection involves a lot of moving parts and a regular commitment to training staff and inspecting work areas, but this type of proactive stance will keep your workers safe and your facilities in accordance with OSHA’s fall protection regulations.
The Occupational Safety and Health Administration (OSHA) recently announced a regional effort to curb serious injuries and fatalities that businesses across the country can learn from. The Safe and Sound Campaign is focused on OSHA’s Region 7, which includes Kansas, Missouri and Nebraska. With a focus on hazards than can arise in a number of industries and have led to increased fatalities in those states, OSHA again demonstrates its role as a leader in the industrial safety field.
Addressing 3 serious and potentially fatal concerns
The driving force behind the Safe and Sound Campaign is a recent increase in fatal workplace accidents. OSHA said it conducted 12 fatality inspections across the three states of Region 7 from Oct. 1, 2016 through Feb. 1, 2017. That’s an average of more than two fatalities per month during a five-month time frame, which is significantly higher than previous fatality rates. A previous and similar five-month span, from Oct. 1, 2015 through Feb. 1, 2016, involved seven fatalities – close to half of what was experienced at the end of 2016 and beginning of 2017.
The three types of fatal accidents that increased during the time period involved confined space entry, trenching and excavating and workers struck by motor vehicles. Employee deaths related to incidents with vehicles doubled between the two time frames previously outlined. That’s worth special notice, considering how common it is for workers to perform duties near motor vehicles as well as to tasks related to operating them.
“Workplace safety and health incidents hurt workers and their families, and they cost [businesses] capital better invested in growing their business and creating jobs,” said Kim Stille, OSHA’s Regional Administrator in Kansas City, in a press release from the agency. “By identifying and controlling job-related hazards that can lead to injuries and illnesses, businesses can improve their safety and health programs, save money and improve competitiveness.”
OSHA’s primary goal is to improve employee safety concerns, but the comments from Stille indicate the federal regulator has a holistic view of what safe and healthy workplaces mean for business owners and the economy in general.
Keeping employees safe is critical no matter what tasks they take on.
Making changes for safer workplaces
With all of these scenarios possible across a number of different industries and workplaces, there’s no one type of business to single out. Instead, OSHA assembled a three-pronged guide to improving on these safety concerns. While the Safe and Sound Campaign was developed with the increase in fatalities in Region 7 in mind, the advice shared applies to nearly every business. EHS Today outlined the three components of the OSHA platform:
Leadership and guidance from managers and supervisors: A successful workplace safety program flows from the top down, with managers and other leaders in the business endorsing and supporting it. OSHA specifically recommended that those in the higher positions of a business’ hierarchy ensure they can provide all the necessary resources to keep employees safe, as well as regularly maintain and improve the existing safety program.
Active employee involvement: Just following rules isn’t enough. Employees need to take an active role by looking for potential safety issues and bringing them to the attention of peers and supervisors as appropriate. This inclusive approach means everyone is engaged in the effort to keep their workplaces safe.
Find and fix ahead of time: The find and fix approach means inspections are conducted to find hazards before they harm employees. Regular reviews of facilities help keep workers safe.
OSHA also highlighted the availability of on-site consultation, which businesses can access in all 50 states. Benefits range from improvements to worker safety to a one-year waiver for other OSHA inspections.
Eyewash stations and emergency showers protect one of the most sensitive and vulnerable parts of employees’ bodies when something goes wrong. Having these stations in place is critical to keep workers safe and to comply with the relevant Occupational Safety and Health Administration standards related to them.
OSHA’s rules for eyewash stations were first developed soon after the federal regulator was created in 1970. The organization called for immediate access to suitable stations for rinsing both eyes and the rest of the body when employees could come into contact with injurious, corrosive materials. As Occupational Health & Safety magazine pointed out, OSHA’s definition of these materials centers on the ability of the agent to destroy or irrevocably alter the structure of the bodily tissue contacted after the exposure occurs.
Emergency showers and eyewash stations are crucial for protecting employees working with dangerous substances.
Getting ANSI involved
While OSHA makes it clear that any employees who may be exposed to chemicals or other dangerous substances meeting the specified criteria have access to eyewash stations and emergency showers, it doesn’t define the nature of those precautions. Companies had to deal with about a decade of time where OSHA mandated the inclusion of these emergency safety tools but did not provide broad guidance beyond configuration or installation, excepting quick access for affected employees.
For a clear, visible and roundly accepted method of determining the suitability of eyewashes and showers, a large number of organizations have turned to the American National Standards Institute’s Z358.1 Eyewash and Shower Equipment Standard, OH&S magazine said. That industrial safety standard covers many specifics of eyewash station and shower function, as well as certification and testing, maintenance of equipment and employee training for proper use.
Some major considerations
The ANSI standard allows for both fixed stations and portable ones. Fix stations tend to use potable water as a flushing agent, which is acceptable under the relevant standards and regulations but creates the potential for significant issues as compared to a saline solution or specially treated water. Tap water isn’t meant to be placed in direct contact with the human eye for extended periods of time, and can cause secondary problems.
“Tap water does not have the composition of human tears,” Dr. Henry Edelhauser, director of Ophthalmic Research at the Emory University School of Medicine, told OH&S magazine. “Tears are a naturally buffered, salt solution. Tap water is not buffered, nor does it contain any of the necessary salts.”
As EHS Today pointed out, fixed stations using potable water require regular maintenance to remove any potential contamination from particulate or chemicals. The website highlighted an instance of a technical safety specialist inspecting an eyewash unit and finding a lack of care had caused the water to resemble chocolate milk as flowed out from the station. That potential lack of maintenance is serious and could cause substantial issues for any employees who rush to use such a unit following accidental exposure, up to and including potential loss of vision.
Additionally, placement has to be a priority. The ANSI standard sets the maximum time an employee should have to spend between exposure and reaching the station at 10 seconds. This time element is foundational in the effectiveness of any eyewash station or emergency shower.
Loading docks are an especially common element of workplaces, from grocery stores to heavy manufacturing plants and distribution centers. These vital links in the supply chain make it easier to transport, distribute and sell or utilize many different goods, commodities and raw materials. However, they frequently feature conditions that can lead to serious injuries for employees unless they’re appropriately addressed. With forklifts, trucks, heavy pallets and potentially dangerous heights all involved – just to name a few potential hazards – it’s critical that businesses develop and regularly update industrial safety plans related to loading docks.
Around the edges of the loading dock
Loading docks have so many moving pieces involved that no single safety component or plan will be enough to prevent all injuries or incidents. Everything from the path trucks follow to drop off and pick up their loads to the areas where forklifts and employees enter and exit the area have to be addressed, along with all factors of the dock itself. Those points of entry and egress are a good place to start a safety plan or review.
Liberty Mutual Insurance suggested checking the pavement that leads up to loading docks, in an effort to stop tractor-trailers from encountering potholes and other obstacles as they make the often-delicate approach to the dock. Small disruptions in the blacktop likely won’t cause any problems, but can deteriorate and eventually create a hazard if left unchecked. In a similar vein, signage that alerts workers they’re entering the loading dock area can heighten awareness of the increased potential dangers that exist.
Providing wheel chocks for tractor-trailers parked at the loading dock also goes a long way toward stopping any negative consequences related to the movement of the trailer when it’s loaded and unloaded. Liberty Mutual suggested chaining the chocks to the loading dock, ensuring they remain close by and can easily be used on each new arrival.
Barricades are an effective safety feature for pedestrians walking or working near the edge of the dock. Painting the edge of the dock in safety yellow provides an additional visual cue to everyone working near it.
Loading docks involve a number of hazards.
Moving vehicles and people
“Floor markings and warning signs are strong reminders to be aware of potential dangers.”
Industrial safety barriers, when used appropriately, can prevent a host of issues related to loading dock operations. Their applications range from separating areas where powered vehicles and workers on foot complete tasks to protecting the facility from potential collisions between these machines and walls and other structural support elements, EHS Today said. They’re also an option for guarding the edge of the loading dock from accidental falls.
Selecting the right barriers is a vital step in ensuring their effectiveness. Businesses need to consider the maximum speed of forklifts and other powered vehicles, the maximum loads they carry and the space needed for the barriers to effectively absorb impacts. The use of fixed or mobile barriers is another option to weigh, and both may be desirable or necessary depending on the specific needs of a given facility.
Beyond barriers, floor markings and warning signs fill important roles as reminders to be aware of other people and vehicles. Designating paths on the work floor won’t eliminate every potential collision, but it will reduce the chances of those incidents occurring. Raising awareness is a necessary element for everyone involved. To that end, place appropriate warnings on overhead hazards, like pipes. Marking and padding corners is another safety component that can prevent especially dangerous and costly collisions.
Keeping staff educated and informed
Training is critical for everyone who works in or near loading docks. One of the most obvious needs is for every employee operating forklifts and similar equipment to be trained and certified under the Occupational Safety and Health Administration guidelines. Staff who work on foot in these areas also need to understand what all the relevant safety markings mean and the potential for danger that exists when working near powered vehicles. Reinforcing the need to take personal safety seriously and maintain awareness of moving machinery can make the difference between an accident and a startled, but safe, worker.
Loading dock safety should be a regular consideration for staff and safety managers. With the right approach, training and tools in place, businesses can create the safest situation possible.
Ladders are common in a variety of industrial and manufacturing contexts. Whether they’re fixed in place or portable, ladders give employees quick access to anything they might need to work or interact with above ground level. However, ladders are also a leading cause of workplace injuries.
The widespread nature of ladders means accidents are common
“Ladder safety is No. 7 on OSHA’s list of most common workplace citations.”
The Occupational Safety and Health Administration’s most recent list of common workplace safety violations placed fall protection at No. 1 and ladders specifically at No. 7, wrote Thomas Gallasi, OSHA director of enforcement programs, in a Department of Labor blog post. While the numbering of the list changes somewhat each year, fall protection and ladders are frequently seen in the top 10. Safety + Health magazine cited Bureau of Labor Statistics data about the 150 deaths and 20,000 nonfatal injuries involving ladders in 2015, the most recent year for which complete data is available.
The nature of ladders means they’re useful in nearly every industry, and either regularly or heavily used in many. However, they also account for a large number of workplace injuries, up to and including deaths. How can businesses effectively address the potential dangers associated with ladder use? The American Ladder Institute is spearheading an initiative in March known as National Ladder Safety Month, a six-step program that aims to boost understanding of safe, effective ladder utilization.
The ALI, which develops general ladder safety standards and serves as a trade group for 16 U.S. manufacturers of these tools, has the full support of OSHA behind National Ladder Safety Month, Safety + Health reported. According to the ALI, the initiative aims to:
Decrease the incidence of injuries and deaths involving ladders.
Issue more ALI ladder training safety certificates.
Lower the position of ladder-related citations on OSHA’s top 10 most frequent violation list.
Increase the overall occurrence ladder inspector trainings.
Raise the number of businesses that adequately and safely dispose of old, broken or otherwise unsafe ladders.
Ryan Moss, ALI president, said the initiative’s core goal is making ladder use safer.
“What if we could make a difference and get that guy home at night?” Moss said to Safety + Health. “What if the guy that was going to pass away today, what if his day came and went, and he went home to his kids and got to play soccer with them or went to the recital or went on a date with his wife? If we did our job right, he would never know that today was his day. The American Ladder Institute, the board and everybody else embraced this and said, ‘Yes, let’s do it.'”
Ladder safety is an important component of many different industries.
Improving ladder safety for your business
The ALI’s online resources are a good place to start, offering free guidance to safety managers and staff. There are plenty of options available from organizations like OSHA to improve industrial safety as well.
OSHA’s portable ladder safety Quick Card offers a comprehensive view of how to safely use these tools in a small package. Covering all concerns from checking the immediate surroundings for potential electrical hazards to ensuring proper, three-point contact with the ladder at all times, this guide is a useful reminder of all the major elements of ladder safety. It specifically addresses potential dangers that may be glossed over when employees are working quickly or under pressure to complete a task, like using the top of the ladder as a step. Following the guidance provided can mean the difference between a safe and successful job completed and the potential for serious injury or death.
OSHA’s Fall Protection Standards page goes further to offer businesses in-depth information about a variety of tools used by employees to work above ground level. The page offers easily visible links to the standards for ladders, as well as stairways, scaffolds and similar systems. For safety professionals who want quick access to standards, OSHA’s regulatory agenda, Federal Register notices, letters of interpretation and other statements made by the federal regulator about working from heights, this is the place.
A strong fall prevention strategy requires access to training materials, effective communication with employees and the implementation of any necessary equipment and safeguards. Consider providing your staff with a refresher on proper ladder use during National Ladder Safety Month.
Back in October, the U.S. Occupational Safety and Health Administration proposed 18 rule changes as part of its Standard Improvements Project-Phase IV.
One of those potential rule changes is the reporting of job-related hearing loss. In the time since that proposal was unveiled, the rule has led to disagreements between OSHA and unions across the country.
The CISC opposes the rule because it would potentially cause confusion, as the change overlaps with existing OSHA regulations. Currently, under 29 C.F.R. 1904.10(b)(6)), employers aren’t required to record hearing loss if health care professionals determine it wasn’t caused by work or significantly aggravated by work site noises.
But under 29 C.F.R. 1904.5, employers have to consider injuries and illnesses as work-related if conditions contributed or significantly aggravated a preexisting illness or injury, explained Bloomberg BNA. If the rule is finalized, employers would potentially be required to record hearing loss injuries they wouldn’t have had to in the past. In its letter, the CISC stated the rule would add extra compliance costs without an assessment of benefits.
Additionally, the requirement may be seen as subjective and open employers up to unforeseen citations.
“Consequently, these substantive changes should be subject to the traditional notice and comment rulemaking procedures as opposed to the more informal SIP procedure,” the CISC wrote.
OSHA wants to change how hearing loss injuries are recorded.
Major union supports proposal
Not all industry groups are opposed to OSHA’s proposed rule, however. The Laborers’ Health & Safety Fund of North America voiced its support because employers already record few hearing loss injuries. In a letter, the LHSFNA said it’s OK with the idea of recording all hearing loss instances, even if work wasn’t a primary contributing factor.
“It is consistent with OSHA’s compliance directives and interpretations of the standard and is particularly important in construction where chronic conditions develop over time across many different workplaces and employers,” the LHSFNA wrote. “Hopefully this change will lead to greater ascertainment of hearing loss cases in construction and a more accurate view of the scope of this significant problem.”
OSHA hasn’t provided a timetable regarding if and when the proposed rule might be finalized or discarded. Either way, employers should still strive to create safe work site conditions to avoid the potential for hearing loss.
Reduce noise exposure
According to OSHA, approximately 22 million workers are exposed to damaging noises every year. Nearly $242 million is spent annually on workers compensation for hearing loss disability. Additionally in 2016, employers were collectively fined over $1.5 million for failing to shield employees from harmful noises.
Employees can reduce noise exposure by identifying warning signs of loud noises and controlling those hazards by implementing a hearing conservation program.
A program needs to be created when worker noise exposure is equal to or greater than 85 decibels over an eight-hour exposure period.
Warning signs
Noises are a health issue if employees experience any or all of the following signs:
Temporary hearing loss after leaving work.
Having to shout at a co-worker when he or she is an arm’s length away.
Experiencing humming or ringing in the ears after leaving work.
Engineering controls
If employees complain of harmful noises, companies may be operating work sites in violation of General Industry Standards 29 C.F.R. 1910. Employers will need to make plans to reduce decibel levels through engineering controls, a process that involves replacing or modifying equipment at its noise source. Examples include lubricating machines, placing barriers between noise sources and employees, isolating the noise source and choosing low-noise machinery.
A hearing conservation program helps protect a worker’s hearing.
Administrative controls
Employers and safety managers should strive to keep their workers out of harm’s way by reducing their exposure to loud noises. Administrative controls can be any of the following:
Keeping workers a suitable distance away from loud equipment.
Limiting the time an individual spends at or near a noise source.
Allowing workers to spend time in a quiet area, such as a sound proof room.
Operating machinery only when fewer people will be exposed.
Protective gear
PPE also plays an important role in protecting workers from loud noises. Hearing protection devices like earmuffs and plugs limit a worker’s exposure to loud noises. However, OSHA stated those devices should complement engineering and administrative controls.
Additional steps
A hearing conservation program should also incorporate key elements, from measuring decibels, testing workers’ hearing levels and informing them of the dangers of loud noises.
While it remains to be seen if OSHA decides to change its hearing loss recordkeeping rule, companies should still limit loud noise liabilities.
Employers should contact Total Safety for more helpful methods and gear to protect employees from hazardous noises.
During the final days of the Obama administration, the U.S. Occupational Safety and Health Administration issued new instructions under its Process Safety Management program that affect the chemical national emphasis program.
According to Bloomberg BNA, the update (dated Jan. 17) says more chemical facilities and oil refineries will be subject to closer inspections by OSHA regulators. The rule is scheduled to become effective March 17, 2017.
Why introduce changes?
The old NEP was limited because inspections were confined to chemical facilities likely to only have used ammonia for refrigeration, facilities that likely used ammonia for refrigeration or sites where highly hazardous chemicals other than ammonia were used.
Thompson Hine LLP, in a Lexology brief, stated OSHA justified a need for the new NEP by highlighting the 69 enforcement actions brought against chemical facility employers in the last five years under its previous NEP. The safety agency also issued 24 enforcement actions on petroleum employers. Each enforcement action resulted in a fine of at least $100,000. Overall, Bloomberg BNA reported In total, OSHA issued 727 violations totaling nearly $3.1 million in fines in 2016.
The National Law Review further stated that OSHA believes highlighting the number of fines and a dollar amount shows the need for continuing and strengthening a PSM-focused enforcement system.
Chemical facilities may be subject to further scrutiny under new OSHA rules.
Who does the change target?
Safety BLR said the new NEP expands required regulatory compliance to facilities housing chemical amounts at or greater than quantities listed in the PSM program under standard 29 CFR 1910.119. Additionally, OSHA inspectors can also utilize data from the U.S. Environmental Protection Agency’s Risk Management Program to further identify facilities for closer inspections.
When the new NEP is implemented, OSHA plans to compile a list of facilities to inspect across OSHA Regions I-X at the start of every year. Facilities previously cited for PSM violations between Jan. 1, 2000, to Sep. 30, 2015, will receive stricter scrutiny. However, facilities looked at within the last three years won’t be subject to inspections under the revised NEP.
OSHA also plans to place identified facilities into one of four groups:
Chemical manufacturers.
Refiners.
Employers whose primary hazardous chemical is anhydrous ammonia.
All others.
If OSHA identifies a facility housing chemical levels above permissible levels (as defined in Appendix A of 29 CFR 1910.119), those facility managers will be required to take steps to reduce or avoid the risk of unplanned release.
What steps do facility managers have to take?
The National Law Review explained that under the new instructions, facility officers need to review their RMP. Additionally, they’ll have to look over OSHA citations from the last six years — if they exist.
During an inspection, an OSHA inspector will provide a list of questions facility managers have to answer, and those questions will be pulled from the third edition of Guidelines for Hazard Evaluation Procedures.
Facility managers will also have to review design codes, equipment and on-site contractors to ensure those third-parties follow safety programs as well.
Impact remains unclear
While OSHA has laid the groundwork to target more chemical facilities and refineries, the impact of the change remains unclear because OSHA itself is shrouded in uncertainty.
As of late February, the U.S. Department of Labor still remains without a secretary after Andrew Puzder withdrew his nomination. President Trump’s new nominee, Alexander Acosta, is still awaiting his hearing before the Senate Committee on Health, Education Labor and Pensions.
Without a new Secretary of Labor, OSHA remains without a Senate-appointed leader too. But when new leaders are confirmed, it’s possible they’ll delay, revise or rescind the rule before its implementation date.
Until the political uncertainty at OSHA subsides, chemical facility managers should still place a high priority on safety.
Chemical facility employees need to keep their workplace safe.
Proper housekeeping leads to safer workplaces
Chemical Engineering magazine stated that while larger safety issues in chemical process facilities (such as chemical handling, storage and personal protective equipment) are important, facility managers can’t ignore small safety issues. Often, smaller incidents occur due to poor housekeeping procedures.
In an interview with Chemical Engineering, Rick Morgando from Kafko International, said facility managers should emphasize the importance of keeping work areas clean.
“The buildup of spills, dust and other hazards will certainly become safety issues if the cleanup of process and other facility areas is not a high priority,” said Morgando.
Facility managers can ensure employees keep work areas safe by providing them with the right tools and cleaning equipment from Total Safety.
Lockout/tagout has been an integral part of workplace safety since its creation in 1989. The process of controlling hazardous energy prevents approximately 50,000 injuries and 120 fatalities annually, according to the U.S. Occupational Safety and Health Administration.
Simply put, lockout/tagout works. But OSHA recently proposed a revision to its compliance standard that has employers worried.
OSHA wants to remove “unexpected” from rule
According to OSHA’s Control of Hazardous Energy Standard (29 C.F.R. part 1910.147), the lockout/tagout standard oversees “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.”
During the fall of 2016, OSHA proposed removing “unexpected” from its lockout/tagout description. It may seem like a small change, but it could have larger repercussions throughout the workplace.
Why is there controversy?
According to Healthcare Packaging, Bruce Main, president of design safety engineering, told attendees at November’s Pack Expo that removing one word will essentially require all energy sources to be locked out, not just unexpected sources of hazardous energy.
“This means that new technology or controls designed to enable safe and quick access for necessary tasks will be prohibited,” said Main.
In Main’s point of view, the proposed change will especially impact machine suppliers whose equipment is used across many industries.
Bloomberg BNA noted how The Graphic Arts Coalition wrote to OSHA that removing “unexpected” would put more workers’ lives in danger throughout industrial workspaces. Even the manufacturer Siemens AG called the proposed change out of line with global standards and proper manufacturing standards.
Adding to the negative reaction to OSHA’s proposal is the U.S. Chamber of Commerce. The lobbying group said OSHA understated the costs of complying with an updated rule (if it’s finalized).
OSHA’s proposed change to lockout/tagout has stirred controversy.
Why was the change proposed?
Given the controversy and strong pushback, it’s natural to wonder why OSHA would even consider making this change. OSHA believes removing “unexpected” would clear up confusion. The agency said safety procedures are ignored during a machine’s startup phase because releasing stored energy as a machine starts isn’t considered unexpected.
Yet a 1996 federal appeals court decision stated that machines that warned employees during the startup procedure don’t technically release energy unexpectedly.
It remains to be seen if OSHA will revise its proposal following a commenting period that ended Dec. 5. But it won’t hurt if employers understand the potential impact this change may have on a workplace.
Employers may have an extra burden
First, employers may have to revise their existing safety plans, in addition to their lockout/tagout procedure.
But the biggest – and arguably most controversial – change means employees would likely face extra regulatory burden. Essentially, employers would now need to expand their lockout/tagout procedures to cover equipment that previously didn’t need to be locked out.
And as the Chamber of Commerce stated, companies would face increased costs by adding more lockout/tagout equipment to their workplace.
Given these changes, some organizations believe a wholesale change is needed if OSHA wants to change how hazardous energy should be controlled.
Lockout/tagout’s future
Even though lockout/tagout is necessary at many work sites, employers still struggle to meet compliance. According to OSHA, failure to control hazardous energy accounts for nearly 10 percent of serious injuries in industrial workplaces.
Now might be the time to consider overhauling the lockout/tagout standard, which has remained static since its inception.
Leading the charge is the American National Standards Institute Committee. In an interview with EHS Today, Todd Grover, global senior manager for applied safety solutions at Master Lock, said OSHA’s current zero-risk blanket approach may not always be suitable in 2017. Having to completely shut down a machine may interfere with tasks around the workplace.
Another issue with lockout/tagout in its current form is companies have difficulty complying with the standard. According to Grover, only 1 in 10 employers has a credible lockout/tagout program in place, 60 percent try their best to meet compliance and 30 percent have no lockout/tagout procedure.
“Only 1 in 10 employers have a credible lockout/tagout program in place.”
Those numbers need to change. Bridging that gap and modernizing lockout/tagout is the new ANSI/ASSE Z244.1 standard, based on best practices in manufacturing.
“Lockout, in its essence, is a procedural or administration step in the hierarchy of controls. Its effectiveness is dependent of employers and workers,” said Grover.
ANSI’s new standard emphasizes scalability. Since it’s a living program, employers can make changes to their lockout/tagout procedure if new machines are added or production lines are expanded.
Keep in mind however, that ANSI/ASSE Z244.1 is not law – it’s simply a best practice. It’s up to companies if they want to complement OSHA’s lockout/tagout rule with ANSI’s standard.
As machines get more advanced and manufacturers include safety warnings regarding hazardous energy, OSHA faces the possibility of overhauling its lockout/tagout procedure. One small change already ignited a storm of opposition, so rewriting the rule to work in 2017 and beyond may be a possibility.
But if companies want to employ best practices, they should consider implementing the ANSI/ASSE Z244.1 standard.
Above all, employers need to ensure a lockout/tagout procedure is in place to protect workers from hazardous energy.
For more information on lockout/tagout and best practices to employ, visit Total Safety.
Falling from heights onto a working surface is one of the leading causes of accidents and fatalities in the workplace, according to the U.S. Occupational Safety and Health Administration. To combat this issue, OSHA issued a final rule to update its general industry walking-working surfaces standard that pertains to fall hazards, trips and slips. This final rule went into full effect Jan. 17 and has a substantial impact on employees and employers.
The effect on employees
Nearly 112 million workers at 7 million work sites are affected by OSHA’s final rule. The majority of workers affected by this updated rule range from warehouse workers to painters. This rule doesn’t apply to the construction industry (it has its own fall standards).
“The new standards may prevent 29 fatalities and 5,842 injuries annually.”
OSHA believes its updated standard will better protect workers in general industry occupations because standards have been updated to reflect a modern work site. Additionally, OSHA added inspection and training requirements.
Employees will be glad to know this final rule incorporates new technologies, national standards and best practices so they’re fully projected while working, Assistant Secretary of Labor for OSHA, Dr. David Michaels, said in a press release. Employees will likely find comfort knowing that fall protection equipment must be provided if they’ll be working along unprotected sides or edges 4 or more feet above a lower level.
“The final rule will increase workplace protection from those hazards, especially fall hazards, which are a leading cause of worker deaths and injuries,” said Michaels.
The new standards may prevent 29 fatalities and 5,842 injuries annually.
The effect on employers
Ultimately, it’s up to the employers to ensure their employees work in safe conditions, and that should be their No. 1 priority. Otherwise, they’re risking the lives of a dedicated workforce and drawing the attention of OSHA inspections.
Understanding training requirements
Employers are now required to train workers on how to use personal fall protection equipment. Employees also need to be instructed (or retrained) on how to work in hazardous situations. OSHA developed three main training actions. Workers must be taught to:
Identify and minimize fall hazards.
Utilize personal fall protection systems and rope descent systems.
Maintain, inspect and store fall protection systems.
Choosing fall protection systems
One of the biggest changes OSHA decided to enact was to provide employers with greater flexibility when choosing a fall protection system.
For many years, employers have had to use guardrails as a primary fall protection method. While guardrails are no doubt helpful pieces of equipment, they aren’t always the most practical choice depending on the work site. Employers will be able to choose a fall protection system they believe works best. This approach has been utilized in the construction industry since 1994 and has worked to great effect.
Per OSHA, employers can choose from the following fall protection system options:
Safety net system.
Positioning system.
Travel restraint system.
Personal fall arrest system.
Ladder safety system.
Guardrail system.
Rope descent system.
Employers will also need to ensure their ladders are up to par. Falls from ladders account for approximately 20 percent of fatal falls and lost work-day injuries. OSHA’s final rule requires fixed ladders support the intended maximum load, while portable ladders should support about four times their designated maximum load.
OSHA’s new fall standards rule is now in effect.
Updates made to Fall Protection Code
If companies seek further guidance on purchasing fall protection equipment, they should adhere to the newly released ANSI/ASSE Z359.1-2016 standard, also known as the Fall Protection Code. It goes into effect Aug. 14, 2017, Occupational Health & Safety reported.
The code – developed by the American National Standards Institute – is the most current way to ensure equipment meets fall protection standards. While not a law, the standard is widely followed throughout the general industry. This guide should be part of organizations’ overall safety plan and be referenced when purchasing fall protection equipment.
A lot is changing in terms of fall protection standards from OSHA and new equipment guidelines from ANSI. While everything may seem overwhelming, employers have time to meet these new compliance standards.
The updated provisions will go a long way toward improving worker safety. If employers need new fall protection equipment, they should contact Total Safety today.
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