SAFETY SOLUTIONS: Have You Recently Conducted Your Required Safety & Health Program Audits?

In every Safety Solutions article I try to write about current issues that have important information for our readers and especially to employers in the plastic distribution and fabrication industry. The first thing that I find when visiting a client’s worksite to conduct a mock OSHA safety & health audit is that, although the employer has a formal and written safety & health manual, it has not been read. I find that the owners, managers, supervisors, and especially the employees, have not read the information that is in this important document.

In a high percent of sites that I have visited or conducted expert witness work for, I found that rarely do my clients know what that formal and written safety & health manual contains. I typically find the following unsafe conditions:

• Employees have not been properly trained or the employer is not enforcing the information that is mandated in their own safety & health written program or OSHA standards.
• Machines are not properly safeguarded or the employees are not using the machine guards that are on the machines.
• Management is not ensuring that employees are following OSHA mandated lockout & tryout procedures. In 80% of my audits, the employer has failed to follow OSHA 29 CFR 1910.147 LOTO standards by conducting at least annually their required LOTO periodic audit.
• Management is not ensuring that chemicals are properly labeled and even worse, employers are allowing employees to eat and drink on the factory floor.
• Employers are not testing their eyewash and showers weekly and when I ask for the testing records, they usually do not have them.
• Fire extinguishers are not inspected monthly.
• Employers have not properly trained their forklift operators and have not recertified them at least every three years. Most operators have never been trained in the forklifts owners/operators manual. Well it’s 2018 and most of these standards have been in place since 1971. OSHA enforcement is on the rise and penalties for employers who do not follow the regulations are higher than ever. Here is some information on just two of the latest plastic related companies that OSHA recently visited.

Do you have that kind of money to pay for citations for not following OSHA rules?

OSHA inspected the plastics manufacturer on Oct. 2, 2017, in response to a complaint alleging unsafe workplace hazards, and imminent danger conditions from blocked emergency exits. A health inspection was also conducted on Oct. 11, 2017, after an inspector’s initial readings indicated employee exposure to excessive noise levels.

OSHA cited the employer for failing to administer a hearing conservation program; exposing employees to amputations, electric shock, and burns; allowing employees to use equipment without proper guarding; failing to control hazardous energy; and failing to train powered industrial truck operators.

The company has 15 business days from receipt of its citations and penalties to comply, request an informal conference with OSHA’s area director, or contest the findings before the independent Occupational Safety and Health Review Commission.

BELLEVUE, OH – The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) cited a Bellevue-based plastics company for multiple safety violations after an inspection found employees exposed to fall, machine, and electrical hazards. OSHA proposed penalties of over $261,000.

OSHA investigators determined that this employer, which operates as a plastic services company exposed its employees to crush injuries, burns, and fall hazards while they conducted maintenance on plastic injection molding presses. Inspectors cited the employer for failing to ensure employees had adequate personal protective equipment and clothing, and for permitting the use of damaged electrical devices.

“Using proper safety controls, and removing damaged devices from service can protect employees from exposure to known hazards in the workplace,” said Kim Nelson, OSHA Toledo Area Office Director.

Each of these citations that these companies received could have easily been avoided. We have covered all of these topics and they are available on www.plasticsmag .com, click on Safety Solutions. We love to hear from readers and I know that we can help you and your company comply with these often sited violations.

If you would like an OSHA Mock Inspection, Podojil & Associates, Inc. has over 45 years of direct OSHA experience and can conduct an OSHA Mock Inspection of your facility at an affordable price.

For more information, click on the author biography at the top of the page.