HOW DO YOU RANK?

The Indiana Occupational Safety and Health Administration (IOSHA) recently issued it’s annual list of the top 25 standards most frequently cited during 1998. The most surprising thing about the list is that the Hazard Communication Standard (HAZCOM) is still in the “top ten”. Manufacturing sector employers have had to deal with the HAZCOM rules since 1986. What
makes this standard so difficult?

Two often repeated cliches are “The devil’s in the details” and “Always read the fine print”. They may hold the key to the problem for employers. The number 2 violation on IOSHA’s list is no written HAZCOM program. The written program is a required statement of commitment, management structure and tools used to put a HAZCOM program in place. It is difficult to imagine how this element could be missing. One company had purchased a fill-in-the-blank manual from a commercial catalog and never used it. Other employers were under the impression that only a book of Material Safety Data Sheets (MSDS) was needed. The written program is an easy violation for the inspector to find since it is usually the first thing requested.

The number 4 violation on the list is also part of the HAZCOM standard. This one is the lack of employee information and training. Employees must be given the information needed to work safely with the chemicals needed to do their assigned tasks. This includes work practices, sources of information (labels and MSDS), available personal protective equipment, and engineering controls. In a recent article we discussed the need for target organ information which was a recent addition to the list of information that must be provided to employees.

The top three equipment violations (numbers 1, 3 and 5 on the list) were familiar items. The first is general machine guarding. Citations can result if guards are broken, damaged, inoperable or missing. On older equipment guards may be cumbersome and bad habits may develop on the shop floor. Number 3 on the list relates to the tongue guard on abrasive wheels. In many cases the guard is present, but not properly adjusted. This is a very easy violation for the inspector to find. Some companies have asked their safety committee members to watch out for machine guard problems. Team members can do periodic observations outside their customary work areas to find potential problems before the inspector arrives. It sometimes helps to have a “fresh” pair of eyes looking at the situation you see (and may overlook) every day. The number 5 citation is exposed live electrical parts. One common source of this is missing blanks in breaker boxes. It’s an easy thing to overlook and results in a very easy violation for the inspector to find. When you inspect the electrical boxes for missing blanks, be sure to note that all doors close securely. It is also necessary to have the correct voltage clearly marked on each box. That was the number 10 citation on the list.

Citation number 6 relates to the recently revised Personal Protective Equipment Standard (PPE). Each employer is required to do a hazard assessment for all tasks and operations in the workplace. This hazard assessment is designed to identify the type of injury that could occur, the type of PPE that would help prevent injury and the likelihood that the injury may occur. The employer must then certify that the hazard assessment is complete. That certification is an overlooked step in many programs. As new machines and processes are added, be sure to expand the hazard assessment to include them.

Citation number 7 covers the written fire and emergency plans. Most employers will have a map or chart posted showing the exits, but may not have a written plan to address the related issues. OSHA expects you to have a plan for tornados, sheltering-in-place, communicating evacuation instructions and establishing an evacuation assembly area. It is necessary to have a mechanism to take a “head count” in case of evacuation. If a chemical emergency requires your employees to stay indoors, do you have a mechanism to turn off all sources of outside air? This standard has been a high priority item on OSHA inspections since the tragic chicken plant fire in North Carolina a few years ago. Citation number 23 was issued for improperly marked exits. If your shop has been remodeled or expanded, be sure that all exit signs are properly located. Improper signs are found on interior walls which used to be exterior walls. And they are found on doors that are n ot clearly accessible because equipment has been relocated. It is important that a main exit aisle be at least 36 inches wide and not blocked by carts, machinery or storage of combustible materials.

Number 8 on the citation list is floor load limits. This refers primarily to mezzanines and lofts. It is easy to forget that a load limit needs to be posted if the surface is accessible only by forklift. The inspector just has to look up to find this one. Citation number 18 is frequently found at the same time. All open sided raised platforms, higher than 4 feet off the floor, must have railings and toeboards. If you have a stairway leading to the mezzanine be aware of the width. IOSHA recently issued a citation for a stairway wider that 22 inches that only had one railing. This happened in a newly constructed building.

The infamous OSHA 200 Log was the subject of citation number 9. Even though OSHA has promised for the last three years to replace this document with a simpler one, employers are still required to use the old 200 form. Most inspectors will ask to see copies of logs for at least the past two or three years. Problem areas can be incomplete entries, lack of totals and improperly classified information. As part of the new outreach philosophy, these violations do not usually carry a fine. However, if you do not have the log prominently posted during the February 1- March 1 time period that’s an easy violation for the inspector to find.

“Permanent path to ground”, or the three prong plug violation made the list at number 11. Be especially aware of this problem with the approach of warm weather. Employees using personal fans can trigger an easy citation. Using one of the hardware store adapters will not solve the problem. Employers need to also check for personal appliances used in break areas. A vendor offered a small refrigerator to one shop for storage of a consumable material. The IOSHA inspector issued a citation because of an improper plug.

Lockout/Tagout didn’t appear on the list until number 13. Lack of a written program, lack of dedicated locks and failure to do an annual review were some of the reasons that led to these iolations.

None of these top listed citations are for exotic or unusual items. Focus on the everyday common programs and standards will help your shop stay off the citation list for 1999.