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Occupational Safety Blog

By Jim Stanley, former No. 2 official at OSHA and President of FDRsafety


Archive for April, 2010

5S: Getting your hands dirty to clean things up

April 29th, 2010

If you read my first two blog posts about 5S, you should have a better understanding of the “what” and “why” of 5S. This blog will help you understand the “how.”

A detailed checklist is helpful to assure that cleaning materials, trash, temporary storage and other necessary items are in place to assure a smooth workshop. Participants report wearing work clothes as 5S requires folks getting their hands dirty.

On the day of the kaizen, (kaizen is Japanese term that equates to continuous improvement) event, the team receives an introduction to 5S and the steps they must follow. After moving to the project site, they spend a few minutes writing a “Purpose Statement” to guide their work. (This is where “effective isn’t perfect” comes into play – - the Purpose Statement might change but it helps organize thought to get going quickly.)

#1 Sort

  • Items of no value are immediately trashed
  • Items with value but not meeting the purpose of the area being 5S’d are sent to a temporary storage area for later disposition
  • Consider the 7 Forms of waste in Sort and all steps of 5S. Remember the acronym COMMWIP:
  • 1. Correction (Errors)
    2. Overproduction
    3. Motion (people)
    4. Material movement
    5. Waiting
    6. Inventory
    7. Process

  • Items that are not present but could add value are identified for follow-up.

# 2 and # 3 Straighten and Shine

  • Items are organized for easy access
  • Everything is deep cleaned (more than a superficial wipe)
  • The goal is to organize items most often used to be easy to see and easy to get.
  • Steps 2 and 3 are usually done concurrently as dictated by common sense.

#4 Standardize

  • Use labels, tape, written instructions and other forms of visual controls (e.g. colored stickers) to enhance understanding. Those who use the area should be able to quickly obtain what they need when they need it.
  • This is the step where elements of the standard are written on an 8 ½ x11 sheet of paper adjacent to a plan view diagram of the area itself. This sheet is placed in a plastic protector and affixed to a wall in a convenient and visible location.

5 Sustain

  • During the kaizen workshop, another 8 ½ x11 form is completed showing who is to do the inspection along with the second level person who validates that the inspection takes place as prescribed. It, too, is placed in plastic and affixed to the wall.
  • The most difficult part of 5S is the ongoing part of sustain where the improvements made are maintained according to the standard.

5S Workshop Summary

  • Usually takes 6-8 hours
  • 30-80% savings in inventory and floor / shelf space is common
  • Tasks associated with the project become faster and easier

The outcome is an organized area, but…
The real value is using 5S to help the team understand how to identify and eliminate waste of which safety of employees is foremost.

For more information on these and similar topics, you may be interested in joining the SHE, sustainability and lean group on LinkedIn

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OSHA plan to increase penalties surfaces in memo from Michaels

April 27th, 2010

On April 22, David Michaels sent a letter to OSHA’s 10 regional administrators and the subject was administrative enhancements to OSHA’s penalties. The penalty changes look like they will become effective in the next several months.

This plan is separate from OSHA’s proposal to require employers to have accident and illness prevention programs, announced Monday (April 26) and outlined in my previous post.

Here are details on the penalty plan:

Time frame for “history”: The time frame for considering an employers’ history of violations will expand from the current three years to five years. If an employer has been inspected in the last five years and had no serious, willful or repeat violations and hasn’t had a failure-to-abate notice, the employer will receive a 10 percent reduction for history. Otherwise there will be no 10 percent reduction in penalties.

Circumstances for 10% increase: If an employer has been cited by OSHA for any high-gravity, serious, willful or repeat violations, or has been cited for a failure to abate notice in the previous five years, they will receive a 10 percent increase in their penalty, up to the statutory maximum.

Repeat violations: The time period for repeated violations will be increased from three to five years.

Reduction for using independent safety consultant: Area directors are authorized by this memo to offer up to a 30 percent penalty reduction to employers at an informal conference. Any reduction over 30 percent has to be approved by the regional administrator. Area directors will be authorized to offer an employer with 250 or fewer employees an additional 20 percent reduction if that employer agrees to retain an independent safety and health consultant.

Grouping violations may be optional: Where circumstances warrant, at the discretion of the area director, high-gravity serious violations related to standards identified in the Severe Violator Enforcement Program (SVEP) will no longer need to grouped or combined, but can cited as separate violations, each with its own proposed penalty.

Gravity-based penalties: OSHA will be adopting a penalty determination that provides for gravity-based penalties between $3,000 and $7,000 for serious violations.

Size reductions: No size reduction will be applied to employers with 251 or more employees.

“Quick FIx” reduction retained:The current “good faith” procedures in the field operations manual will be retained. The 15 percent Quick Fix reduction, which is currently allowed as an abatement incentive program meant to encourage employers to immediately abate hazards found during an inspection, will also be retained. However, the 10 percent reduction for employers with a strategic partnership agreement will be eliminated.

Minimum penalty: The minimum proposed penalty after history, size and good faith adjustments will be increased to $500.

Overall impact

Dr. Michaels believes that these changes will generally increase the overall dollar amounts of all OSHA proposed penalties. He believes that the average penalty for a serious violation will increase from approximately $1,000 to an average of $3,000 to $4,000. OSHA hopes that higher penalty amounts will provide a greater deterrent and further encourage you employers to furnish a safe and healthful workplace for all of your employees.

If you have any questions regarding OSHA’s plan and the potential impact on your company, contact me at jstanley@fdrsafety.com or (513) 317-5644.

I expect that this penalty plan, along with the proposed accident and illness prevention program outlined in my other post today will be the subject of ongoing posts to this blog. To have our latest posts delivered automatically to your mailbox, click here.

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OSHA asks new rules on employer safety programs; ups ante on ergonomics

April 27th, 2010

OSHA is launching what agency head David Michaels described Monday as a “long overdue” initiative on injury and illness prevention and plans to increase enforcement on ergonomics. Both initiatives are likely to be extremely controversial.

OSHA is also moving plans to create a combustible dust standard to its long-term regulatory agenda, further extending what has already been a long process. I expect this means the standard is not in our immediate future.

These initiatives and other items OSHA discussed Monday will provide extensive fodder for future postings on this blog. But here are the highlights:

Injury and Illness Prevention Program

The new program would require employers to “find and fix” the hazards in their workplaces. The program “does represent a major paradigm shift for OSHA,” Michaels said in a webcast.

“Employers and others must ‘find and fix’ violations — that is, assure compliance — before a Labor Department investigator arrives at the workplace,” Michaels said. “Employers and others in the Department’s regulated communities must understand that the burden is on them to obey the law, not on the Labor Department to catch them violating the law. This is the heart of the Labor Department’s new strategy.

“We are going to replace ‘catch me if you can’ with ‘Plan/Prevent/Protect,’” Michaels said.
Here is what OSHA said about the proposed program as part of its announcement of its spring regulatory agenda:

“Plan”

“The Department will propose a requirement that employers and other regulated entities create a plan for identifying and remediating risks of legal violations and other risks to workers — for example, a plan to search their workplaces for safety hazards that might injure or kill workers.

The employer or other regulated entity would provide their employees with opportunities to participate in the creation of the plans. In addition, the plans would be made available to workers so they can fully understand them and help to monitor their implementation.”

“Prevent”

“The Department will propose a requirement that employers and other regulated entities thoroughly and completely implement the plan in a manner that prevents legal violations. The plan cannot be a mere paper process. The employer or other regulated entity cannot draft a plan and then put it on a shelf. The plan must be fully implemented for the employer to comply with the ‘Plan/Prevent/Protect’ compliance strategy.”

“Protect”

The Department will propose a requirement that the employer or other regulated entity ensures that the plan’s objectives are met on a regular basis. Just any plan will not do. The plan must actually protect workers from violations of their workplace rights.

“Employers and other regulated entities who fail to take these steps to address comprehensively the risks, hazards, and inequities in their workplaces will be considered out of compliance with the law and, depending upon the agency and the substantive law it is enforcing, subject to remedial action.”

For official OSHA statements on this proposal, click here.

Ergonomics

OSHA earlier announced that it is proposing to revise its recordkeeping regulation by restoring a column on the OSHA Form 300 to better identify work-related musculoskeletal disorders (MSDs). The agency has said that the proposal was not a prelude to proposing a new standard on ergonomics. A previous attempt to create such a standard failed early in the Bush administration.

But Michaels said Monday, “In addition to adding an MSDS column to the 300 log, OSHA will be increasing its enforcement of ergonomic hazards under its General Duty Clause. We are continuing to consider additional approaches to addressing ergonomic hazards.”

Combustible Dust

OSHA also said yesterday it was moving a combustible dust standard to its long term agenda. Here is what Michaels said about that:

“Combustible dust is a priority. However, this is a very complex rule and we are actively doing the necessary research to support this rule. The only reason this is in a long-term action is because the next step, SBREFA Panel Review, is a year out. April 2011 is as soon as we can do the necessary work to initiate a SBREFA review.”

Worried about the possibility of an OSHA inspection? Here’s what to do to be ready.

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