Safety Tidbit 3.45 - Danger - Unattended Forklift

Safety Tidbit 3.45 – Danger - Unattended Forklift

Reference:       OSHA Powered Industrial Truck Standard (1910.178)

According to statistics compiled by the Material Handling Equipment Distributors Association (MHEDA) in 2013, it was estimated that 34,900 serious injuries annually due to forklifts. While onsite this week, I had a great discussion with a very engaged safety manager who asked about unattended forklifts. His workers must get on and off their trucks routinely to do various tasks. So, we started by reviewing the OSHA requirements:

1. When a powered industrial truck is left unattended, load engaging means shall be fully lowered, controls shall be neutralized, power shall be shut off, and brakes set. Wheels shall be blocked if the truck is parked on an incline. [1910.178(m)(5)(i)]

2. A powered industrial truck is unattended when the operator is 25 ft. or more away from the vehicle which remains in his view, or whenever the operator leaves the vehicle and it is not in his view. [1910.178(m)(5)(ii)]

3. When the operator of an industrial truck is dismounted and within 25 ft. of the truck still in his view, the load engaging means shall be fully lowered, controls neutralized, and the brakes set to prevent movement. [1910.178(m)(5)(iii)]

Item 3 above is where this workplace typically falls. The operator is dismounted and within 25 feet of the machine. Unfortunately, the forklift we came across had the load raised and the brakes were not set. The safety manager spoke with the operator and retrained him on the company procedures, lowered the forks and set the brake. 

You all have seen these shortcuts happen in your workplaces. I implore you, when you are walking your plant or site please remind the workers that the small amount of time they shaved off their procedure may cost someone many hours in the emergency room or worse. 

Hope this was helpful and thank you for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.44 - Tanks need love (labeled) too

Safety Tidbit 3.44 – Tanks need love (labeled) too

Reference:       OSHA Hazard Communication Standard

An important aspect of the OSHA Hazard Communication Standard is to communicate to workers the hazards of the contents of various containers found in the workplace. Recently, I have come across various tanks and batch vessels located both inside and outside the facility. Oftentimes, the only label on a tank is a faded NFPA diamond with numbers that were hard to make out.

I asked an employer if they knew what was in a tank located in the maintenance area, they said fuel. I pushed a bit further to ask what the hazard (other than being flammable) to the workers might be. There was no answer. I asked if anyone knew what the numbers on the NFPA diamond meant? Again, no answer. I asked how they use the tanks and they said they routinely dispense from the tank into vehicles and other smaller containers. No PPE was used.

1910.1200(f)(7) states: “The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(6) of this section to be on a label. The employer shall ensure the written materials are readily accessible to the employees in their work area throughout each work shift.”

So, bottom line, all containers in the workplace need to be labeled, even permanently mounted storage and fuel tanks. All employees need to know how to protect themselves from the materials they are required to use.

Hope this was helpful and thank you for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan
P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.43 - Auto Accidents - Do we - Report, Record, Investigate

Safety Tidbit 3.43 – Auto Accidents – Do we - Report, Record, Investigate

Reference:       OSHA Recordkeeping

A worker arrived at the home office very early in the morning to get the company vehicle and drive to the jobsite which was a few hours from the home office. The worker worked a full shift then proceeded to drive back to the office to drop off the company vehicle. On the way back to the home office the worker was killed in an automobile accident.

First question from the client, must they report the fatality to OSHA? Second, must they record the fatality on their Injury/Illness log? A better question, what caused the accident and the loss of a worker? Note: The employer was advised that they did not need to report the incident to OSHA.

The first question is easy (or is it?). All employers are required to notify OSHA within 8 hours when an employee is killed on the job. OSHA explains that employers do not have to report an event if it:

·      Resulted from a motor vehicle accident on a public street or highway (except in a construction work zone);

·      Occurred on a commercial or public transportation system, such as airplane or bus;

·      Involved hospitalization for diagnostic testing or observation only.

Well I guess the answer to our question seems to be “yes” but is really “no.” Letting OSHA know isn’t a bad idea however, other federal agencies are already responsible for taking care of incidents on the highways.

Second question, does the incident get recorded on the company Injury and Illness Log?  OSHA requires each employer required by this part to keep records of fatalities, injuries, and illnesses must record each fatality, injury and illness that:

·      Is work-related [1904.4(a)(1)]

·      Is a new case [1904.4(a)(2)]

·      Meets one or more of the general recording criteria of §1904.7 or the application to specific cases of §§1904.8 through 1904.12 [1904.4(a)(3)]

I think we can agree that this is work-related. It’s a new case and meets 1904.7 “You must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, if it results in any of the following: death, days away from work, …”  Therefore, I think we can answer, the incident needs to be recorded on the employer’s Injury/Illness Log.

Now, since we’re health and safety professionals, let’s look at the last question that I posed above. What caused the accident and the loss of a worker? Remember the purpose of recording incidents on the injury/illness log is not only to track injuries but ultimately, but ultimately to investigate to determine what can be accomplished to keep similar incidents from happening again by learning from the past.

Let’s look at the scenario again (the times are approximate). The worker left his home at 4 AM drove two hours to the home office (6 AM) to pick up the company truck, drove two hours to the site (8AM), worked a ten-hour shift (6PM), drove two hours back to the home office. The worker became fatigued and dosed off at the wheel causing the accident (from the police report – driver fell asleep at the wheel). Final question: Should the employer have had a policy or procedures to help reduce or at least identify work fatigue?

Hope this was helpful and thank you for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.42 - When is an SDS just an MSDS

Safety Tidbit 3.42 – When is an SDS just an MSDS

Reference:       OSHA Hazard Communication Standard

A bit of a short tidbit this week. I was reviewing an employer’s hazard communication program. When I asked, the client said they had SDSs for all their chemicals in the shop. However, when thumbing through the book I noticed some had the heading Material Safety Data Sheet (MSDS).
 

Upon closer inspection, the MSDS sheets were in the sixteen-part format but were missing key parts of the hazard identification section: namely the signal word and hazard statements. OSHA’s 2012 Hazard Communication standard requires “chemical manufacturers and importers to evaluate chemicals produced in their workplaces or imported by them to classify the chemicals. For each chemical, the chemical manufacturer or importer shall determine the hazard classes, and, where appropriate, the category of each class that apply to the chemical being classified. [1910.1200(d)(1)]” Furthermore, chemical manufacturers, importers or employers classifying chemicals shall identify and consider the full range of available scientific literature and other evidence concerning the potential hazards. [1910.1200(d)(2)] Ultimately, employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer or importer for the chemical to satisfy this requirement.

The employer labeled the containers according to the “MSDS.” Unfortunately, when we looked on the manufacturer’s website they had updated the chemical’s Safety Data Sheet with all the correct information.

Bottomline, don’t take on more responsibility than necessary. If the manufacturer labels the data sheet as a Material Safety Data Sheet, then that’s what it is. It is not a Safety Data Sheet as it has not gone through the rigor to include all the information the new hazard communication standard requires the manufacturer to include.

Hope this was helpful and thank you for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.41 - Why 100 Decibels for Noise Abatement

Safety Tidbit 3.41 – Why 100 Decibels for Noise Abatement

Reference:       OSHA Occupational Noise Exposure Standard

                        OSHA Field Operations Manual

As some of you may remember back in 2011 or so, OSHA pushed to start enforcing engineering controls for noise exceeding 90 decibels. Which may have seemed strange as the OSHA Noise Standard, 1910.95(b)(1) states: “When employees are subjected to sound exceeding those listed in Table G-16, feasible administrative or engineering controls shall be utilized.” Which, by the way, the original noise standard was from the first set of OSHA standards in 1971. Therefore, OSHA has never really written an Occupational Noise Standard. However, in the early 1980’s, the Hearing Conservation Amendment was added to the original standard.

An outcome from a 1982 court case and found in OSHA’s Field Operations Manual (FOM):

“Current enforcement policy regarding §1910.95(b)(1) allows employers to rely on personal protective equipment and a hearing conservation program, rather than engineering and/or administrative controls, when hearing protectors will effectively attenuate the noise to which employees are exposed to acceptable levels. (See Tables G-16 or G-16a of the standard).”

This decision and policy came about primarily because, at the time, NIOSH asserted that a comprehensive hearing conservation program was as effective at preventing hearing loss as engineering and administrative controls.

Furthermore, in the OSHA FOM:

“1. Citations for violations of §1910.95(b)(1) shall be issued when technologically and economically feasible engineering and/or administrative controls have not been implemented; and

a. Employee exposure levels are so elevated that hearing protectors alone may not reliably reduce noise levels received to levels specified in Tables G-16 or G-16a of the standard. (e.g., Hearing protectors which offer the greatest attenuation may reliably be used to protect employees when their exposure levels border on 100 dba). See CPL 02-02-035, 29 CFR 1910.95 (b)(1), Guidelines for Noise Enforcement; Appendix A, dated December 19, 1983; or

b. The costs of engineering and/or administrative controls are less than the cost of an effective hearing conservation program.”

So, as you can see OSHA inspectors have been forced to wait until the noise levels are above 100 decibels before engineering controls will be enforced. Meanwhile, hearing loss is one of the greatest occupational injuries plaguing our workforce and degrading worker quality of life. As consultants, we need to look for those feasible engineering and administrative controls and advise our clients so prudent practices can be implemented and the workers protected from occupational noise.

Hope this was helpful and thank you for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan
P.S. If you have an interesting safety or health question please let me know.