Safety Tidbit #11: Man vs. Forklift

A client recently asked: Does OSHA require us to walk through the man-door between areas when the overhead door used for material handling is open? The short answer is no. However, whenever pedestrians and forklifts occupy the same area we have a very hazardous condition.

Forklift operators must be competent to operate the forklift. [1910.178(l)(1)(i)] And, at a minimum, training must be renewed every three years.[1910.178(l)(4)(iii)]  Additionally, the driver must look in the direction of, and keep a clear view of, the path of travel. [29 CFR 1910.178(n)(6)] However, if the load being carried obstructs forward view, the driver must drive with the load trailing. [29 CFR 1910.178(n)(4)]

Helping further to keep man and machine apart, OSHA requires safe clearances to be identified for aisles, at loading docks, through doorways, and wherever you are making turns. Aisles and passageways shall be kept clear and in good repair, with no obstruction across or in aisles that could create a hazard. Permanent aisles and passageways must be appropriately marked. [1910.176(a)] Also, storage areas are to be kept clean and free of hazards (e.g., tripping, fire, explosion, etc.). [1910.176(c)]

As a forklift operator are you doing the following:

1.     Yield right-of-way to pedestrians.

2.     When pedestrians walk across your planned route:

a.     Stop.

b.     Wait until the pedestrians pass.

c.      Proceed cautiously through any congested area.

3.     If an area is cluttered, walk the route first to spot problems.

4.     Check for situations that require a spotter and use one when traveling.

5.     Warn pedestrians, by asking them to move, if there is not sufficient, safe clearance.

6.     Sound the horn at blind corners, doorways and aisles.

7.     Sound the horn or other alarm when you back up.

And as a pedestrian are you:

1.     Be aware that lift trucks cannot stop suddenly. They are designed to stop slowly to minimize load damage and maintain stability.

2.     Stand clear of lift trucks in operation.

3.     Avoid a run-in. The driver's visibility may be limited due to blind spots.

4.     Be aware of the wide rear swing radius.

5.     Use pedestrian walkways, or stay to one side of the equipment aisle.

6.     Never ride on a forklift, unless authorized and the forklift is designed for riders.

7.     Never pass under an elevated load.

So again, whenever man and machine have the potential to occupy the same space bad things can happen. Therefore, I recommend - use the man-door and keep away from the forklifts.

Reference:

https://www.osha.gov/SLTC/etools/pit/workplacehazards/index.html

Safety Tidbit #10: Recording and Recordkeeping for Temporary Workers

So what does OSHA want to know about the injuries or illnesses in our workplaces?  You need to understand, that the recordkeeping OSHA that has put in place is a trending tool.  It enables them to trend injuries in the workplace nationally.  That is why they conduct a data call each year (well either OSHA and/or Bureau of Labor Statistics) and requests the summary records completed by the employer.  But also, OSHA wants to hear about more severe cases (fatalities, amputations, loss of an eye, hospitalizations).  They can then decide to intervene to ensure the employer is conducting a thorough accident investigation and implementing controls to prevent further injuries.  So let’s make the broad assumption that we all know exactly how to complete the OSHA 300 log and when to call OSHA.  What happens when the injured worker is a temporary worker? They’re people too, right?

My question is simple. Why is the safety of the temporary worker any different than that of a full-time or part-time worker? Now you might argue that the temporary agency provides their worker’s compensation. Worker’s compensation gets the worker healthy and takes care of them while they are convalescing. The agency does not know the work conditions, may not know the appropriate training necessary for your specific site and ultimately did not have anything to do with worker’s day-to-day activities.  The agency is really only taking care of the Human Resources portion for the worker.  The safety of the worker still rests firmly with the gaining employer. 

The employer may contract that certain general safety and health training and physical requirements be met prior to the temporary worker coming onsite. However, the employer must give site specific training. For instance, a temporary worker may need to be able to operate a forklift but the employer must ensure they can operate their forklifts under their conditions and verify their proficiency.  Or, for a particular employer the temporary worker must be able to wear a respirator, so the agency ensures they are medically qualified. The agency may even provide fit-testing for a particular respirator and some training.  The employer then must incorporate that information into their company's respirator program and validate the adequacy of the respirator and filters for their hazards, and still provide site-specific training on their expectations with respect to respirator use.

Bottom line, if you direct the activities of temporary workers, you need to record their injuries on your OSHA 300 log.  And, heaven forbid, contact OSHA if the injury is severe enough to warrant the call to the OSHA office (1904.31).  The employer is solely responsible for the safety of their work sites. Safety for all of the workers on the site (Full-time, part-time, permanent, temporary, or for that matter brown, black, blue or green).

Safety Tidbit #9: Hazard Communication Labeling

I’m sure all you readers are aware the 2012 Hazard Communication Standard permitted a phased compliance.  By June 1, 2015 (now obviously past) all chemical manufacturers, importers, distributors, and employers were to comply with the new provisions with labeling being the last item.  Labeling has two compliance dates, six months (December 1, 2015) following everyone’s supposed compliance with the 2012 revision manufacturers will no longer be permitted to ship containers not labeled appropriately.  The extra six months was based solely on economic reasons is supposed to give manufacturers and the like a chance to get rid of their previously labeled stock. The second compliance date for labeling gives employers a full year (June 1, 2016) from when they were supposed to comply with the 2012 Hazard Communication Standard to update their workplace labeling. Also, employers are to provide any additional training as necessary.

So why the extra time for labeling?  Simple, there is a lot of information on the new labels, tags, or marks.  Each original container must have the following: the product identifier, signal word, hazard statement, pictogram(s), precautionary statement(s), and the name, address and telephone number of the chemical manufacturer, distributor, etc. (1910.1200(f)(1)).

Now workplace labeling is getting a full year for compliance. Let’s start with the two exceptions. First, batch containers can continue use signs, placards, process sheets, batch tickets, operating procedures, or other written materials instead of affixing labels to individual stationary process containers.  The alternative method must identify the containers to which it is applicable and conveys the required information. The employer must ensure the written materials are readily accessible to the employees in their work area throughout each work shift (1910.1200(f)(7)).

The second exception is the same as from the 1994 Standard.  The employer does not need to label containers of hazardous materials that are for use by a single employee or immediate use.  The exception assumes that since the employee that is likely to be affected by the material already knows what is in the container because that worker put the material into the container.  Now if you find an unlabeled container lying around the shop, all bets are off, and it’s a good time to challenge the whole Hazard Communication Program implementation.  Specifically, ask them what is in the bottle, their knowledge of the hazard, where is the SDS, can they get the SDS, etc.

Therefore, other than the two exceptions above, all containers are to be labeled with all of the information I presented in the second paragraph.  However, the employer is still permitted to use a reduced labeling system. They can use a product identifier and words, pictures, symbols (NFPA), or a combination, which provide at least general information regarding the hazards of the chemicals. However, the other information required by the hazard communication program must be immediately available to employees.  The tough part of this alternative to having a label that meets all of the requirements is the training necessary.  As I mentioned above if you challenge the employee as to their knowledge of the hazard of the substance how many could pass? They may be able to find the SDS but can they read it and provide the hazard information?  Most often I find they cannot.

So my take home message is to get the label from the manufacturer or use a label that is equivalent to the manufacturer’s label with all of the information and leave nothing to doubt.  Remember, the standard is the Hazard Communication Standard so let’s make sure we are communicating.