The flurry of activity that occurred when your facility received citations after your recent OSHA wall-to-wall visit has finally let up. Following the process explained in the last blog, you posted the citations and the team reviewed each citation to gain complete understanding. Now there are abatement dates that must be met.
As you and your team start work correcting the violations, you begin to feel distraught--you worked hard getting safety processes in place as the new plant safety person. You are disappointed with the outcome of the wall-to-wall and you wonder if the citations are unique to your facility and what you can do differently to avoid citations in the future.
How does my facility stack up? And how do I look for gaps in my planning?
Taking a look at the most frequently cited OSHA violations can offer some perspective. Each year OSHA announces its Top Ten Most Cited Violations for the previous fiscal year (October 1 through September 30). The listing includes both Construction Industry Standards (29 CFR 1926) and General Industry Standards (29 CFR 1910). (NOTE: OSHA uses the term “General Industry” to refer to all industries not included in agriculture, construction or maritime.)
As a manufacturing facility, pay particular attention to the 29 CFR 1910 citations contained within the listing. However, be aware there are circumstances when a general industry facility may fall under Construction Industry Standards. OSHA’s regulations define construction work as construction, alteration, and/or repair, including painting and decorating. (You should check with your legal counsel to determine if construction industry standards apply to your circumstances.)
We will focus on the most frequently cited OSHA violations in General Industry which, during fiscal year 2016, accounted for 7 out of 10 most frequently cited violations. To gain a complete understanding of each standard, refer to the full text via OSHA.
To determine how your facility compares, answer the questions below, with “yes” answers indicating compliance. For each “no,” refer to the full text of the standard to learn more and to determine how to close the gap and avoid a future citation.
And Most-Cited General Industry Standards Are…
Hazard Communication (29 CFR 1910.1200)
1910.1200(e)(1) Do you have a written hazard communication program?
1910.1200(g)(1) If you are a chemical manufacturer or importer, have you obtained or developed a Safety Data Sheet (SDS) for each hazardous chemical produced or imported?
1910.1200(g)(8) Do you have a SDS for each hazardous chemical in your facility? Are SDS’s readily accessible?
1910.1200(h)(1) Is employee training on hazard communication provided at time of initial assignment?
1910.1200 (h)(3)(iv) Does training include details of the hazard communication program?
Respiratory Protection (29 CFR 1910.134)
1910.134(c)(1) Have you developed and implemented a written respiratory protection program, and is it updated to reflect changes in the workplace?
1910.134(c)(2)(i) Do you provide respirators to employees upon their request or do you allow them to use their own respirators? If so, have you determined the use will not create a hazard?
1910.134(d)(1)(iii) Have you identified and evaluated respiratory hazard(s) in the workplace?
1910.134(e)(1) Before an employee is fit tested or required to use a respirator, do you provide a medical evaluation?
1910.134(f)(2) Do you provide a respirator fit test before initial use when an employee uses a tight-fitting face piece respirator?
Lockout/Tagout (29 CFR 1910.147)
1910.147(c) (1) Have you established an energy control program that consists of the following: energy control procedures, employee training, and periodic inspections?
1910.147(c)(4(i) Have you developed and do you utilize procedures for the control of potentially hazardous energy when employees are engaged in the servicing and maintenance of machines and equipment?
1910.147 (c)(6)(i) Do you conduct a periodic inspection of your energy control procedure at least annually?
1910.147 (c)(7)(i) Do you provide training of the energy control program?
1910.147(c)(7)(i)(A) Have authorized employees received training in the recognition of hazardous energy sources, the type and magnitude of energy , and energy isolation and control?
Powered Industrial Trucks (29 CFR 1910.178)
1910.178(l)(1)(i) Have industrial truck operators completed training and evaluation to ensure their competency?
1910.178(l)(1)(ii) Do you require each operator of a powered industrial truck to successfully complete training prior to operation?
1910.178(l)(4)(iii) Do you evaluate the operator’s performance at least once every three years?
1910.178(l)(6) Do you certify each operator has been trained and evaluated to operate powered industrial trucks? Does the certification include the operator’s name, date of training, date of the evaluation, and the identity of the trainer?
1910.178(p)(1) If a powered industrial truck is in need of repair, defective, or unsafe, do you take the truck out of service until it is safe to operate?
Machine Guarding (29 CFR 1910.212)
1910.212(a)(1) Are point of operation, ingoing nip points, rotating parts, flying chips, and sparks guarded to protect the operator and other employees in the area?
1910.212(a)(2) Is the guard affixed to the machine or secured elsewhere, and have you ensured it does not create a hazard in itself?
1910.212(a)(3)(ii) Is the point of operation designed so as to prevent the operator from having any part of the body in the danger zone during the operating cycle?
1910.212(a)(5) Is the periphery of fan blades that are less than 7 feet above the floor or working level, guarded? Does the guard have openings no larger than one-half inch?
1910.212(b) Are machines designed for a fixed location securely anchored to prevent walking or moving?
Electrical-Wiring Methods (29 CFR 1910.305)
1910.305(b)(1)(i) Are conductors entering cutout boxes, cabinets or fittings protected from abrasion?
1910.305(b)(1)(ii) Are unused openings in cabinets, boxes, and fittings closed?
1910.305(b)(2)(i) Does each outlet box in the facility have a cover, faceplate, or fixture canopy?
1910.305(g)(1)(iv)(A) Are you avoiding using flexible cords and cables as a substitute for fixed wiring unless specifically permitted by the standard?
1910.305 (g)(2)(iii) Do you provide strain relief for flexible cords and cables when they are connected to devices and fittings?
1910.303(b)(2) Is your electrical equipment installed and used according to instructions?
1910.303(f)(2) Is each service, feeder, and branch circuit legibly marked at its disconnecting means or overcurrent device to indicate its purpose?
1910.303(g)(1) Is there sufficient access and working space surrounding all electrical equipment?
1910.303(g)(1)(ii) Can you ensure working space around electrical equipment is not used for storage?
1910.303(g)(2)(i) Are live parts of electrical equipment, operating at 50 volts or more, guarded against accidental contact?
Results are in… now what?
When you compare your citations to the Top 10 list, you may not be able to answer yes to each question. If you consistently answered no, consider this an opportunity for continuous improvement in developing your safety process. Keep in mind, OSHA has more than 100 General Industry Standards, and as a new plant safety person you must become acquainted with the standards that apply to your particular type of industry.
One of your best resources to learn more will be the OSHA website, where you can find all the OSHA standards, fact sheets, and training requirements together in one place. You can also reach out for help from experts like Antea Group, who specialize in knowing and understanding all the standards that apply to your business.
Stay tuned for upcoming posts, where we will delve deeper into some of the General Industry Standards to help you in your quest to create a safe and healthful working environment. In the meantime, if you have questions about particular standards and your specific organization, contact us.
Download our complete guide for new plant safety managers here.
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About the Author
Dr. Barbara Boroughf, PhD
Vice President, Comtel Corporation
Barbara Boroughf, PHD, has more than 38 years of experience in environmental health and safety in the manufacturing segment. She is the former Global Vice President of Health, Safety and Environmental Management for Lear Corporation, a Global Tier 1 automotive manufacturer, headquartered in Southfield, MI.
She retired from Lear July 1, 2015. Prior to coming to Lear in 1997, Barbara held various positions within Rockwell International starting with Rockwell in 1978 at their North American Space Operations in Golden Colorado as Safety Manager. She was promoted to Rockwell’s Corporate Director of Health, Safety and Workers’ Compensation, Seal Beach, CA. Currently she is Vice President EH&S Program Development for Comtel Corporation, a sales, engineering and service company and provides written content exclusively for Antea Group.