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Occupational Safety Blog

By Fred Rine, CEO of FDRsafety and former long-time Managing Director of Safety and Health at FedEx, Jim Stanley, President of FDRsafety and former No. 2 at OSHA headquarters and Mike Taubitz, Senior Advisor to FDRsafety and former Global Safety Director for General Motors.


Archive for the ‘Accident Prevention’ Category

Can metal lathes be made safe?

June 23rd, 2014 posted by Mike Taubitz

Mike Taubitz

An article on an Australian safety website described the tragic death of a worker whose coat was caught in a lathe and asked the question that is the title of this article: Can metal lathes be made safe? The article went on to offer the following ideas:

“How can these risks be minimised? A simple interlocked chuck guard connected via a Category 4 control system in accordance with AS 4024.1 that prevents the machine from starting while open will remove or significantly reduce most lathe safety risks….  When lathes need to be run with the guard open during set-up, for example, fit a two-hand control system that allows the operator to run the machine at a safe, low speed, rather than an interlock that can be switched off. With both hands away from the rotating hazards and ejection hazards minimised due to the safe low speed, or jog mode, the operator/setter is protected.”

I agree – partially.  Innovations in safeguarding can often be incorporated when designing and building new machines.  Those same innovations are often not feasible for retrofit – that’s the reason for my passion around the concepts of “Design-in Safety” and “Prevention thru Design” (PtD). The dilemma is that few engineers are even told they have a responsibility to consider occupational safety in the design of machines and systems.  Then, when they get in the real world, they interface with safety people who may not have the technical acumen to deal with issues of design.

Back to lathes.  Before putting on interlocked chuck guards, I would also want to know which tasks cannot be performed with the guard in place – and two hand controls may not work.  When setting up a part in a lathe, you typically bring the tool into position to find the center point/depth of cut.  You must have line of sight and need to move the tool by hand.  It has been a long time since I’ve done that task but I would like someone to show me how two-hand controls could be used during lathe setup!  This is the reason for my constant use of Task Based Risk Assessment (TaBRA).  This methodology identifies when power is needed and those steps where employees may, of necessity, have close contact with equipment.

The problem with work-arounds

Many of the fatalities (over 80 during my career) and serious injuries I have investigated involved a task where the employee had to “work around” the safeguarding to accomplish the task.  Sometimes there is a failure to comprehend all the variables of the work during design of the equipment and/or safety procedures.  Perhaps it is for this reason that ANSI B11.6, the US National Standard for Manual Turning Machines with or without Automatic Control, is mute on the ideas offered in this article.

The ANSI B11 family of general industry machine safety standards is based upon achieving acceptable risk through the good faith application of the hierarchy of controls.  The B11 Committee understands that there is no such thing as zero risk and that employee intervention is necessary for specific tasks that may force use of training, warnings, procedures, administrative controls and PPE to achieve acceptable risk.  Feasibility of engineering safeguards is always a key consideration.

If you think it’s a good idea to never allow a worker to be around moving equipment/machinery, tell that to your mechanic the next time you take your automobile in for troubleshooting or a tune-up.

 

 

 





A well-deserved backseat for OSHA’s I2P2

June 2nd, 2014 posted by Jim Stanley

Jim Stanley

OSHA’s proposed Injury and Illness Protection Program, known as I2P2, apparently won’t be seeing the light of day anytime soon, if ever, and that is a good thing for workers and employers.

The proposed program was pushed back to the long-term action section of OSHA’s spring 2014 regulatory agenda. Placement on the long-term agenda often can last for years and in any event means that it is unlikely to resurface during the current administration.

I2P2 would have required all companies under OSHA’s jurisdiction to implement a safety program with detailed requirements dictated by the agency. The problem, as I and many others have commented, is that no government standards could appropriately address the wide variety of circumstances across industries and employers.





OSHA focusing on increased fatalities on communication towers

March 19th, 2014 posted by Jim Stanley

Jim Stanley

OSHA is expressing concern about an alarming increase in the number of deaths resulting from work on cellphone towers and is pointing to fall protection problems as a major contributor.

In a letter to companies in the communication tower industry, OSHA Administrator David Michaels said the fall protection lapses are occurring because “either employers are not providing appropriate fall protection to employees, or they are not ensuring that their employees use fall protection properly.” In 2013, 13 workers in the industry died at worksites, more than the two previous years combined.

Michaels called on the communication tower companies to train incoming workers, make sure they are provided with fall protection equipment and insure that workers actually use the equipment.

OSHA will consider citing companies for willful violations where the equipment is not provided or not used properly, Michaels said.

OSHA inspectors will be examining contracts “to identify not only the company performing work on the tower, but the tower owner, carrier, and other responsible parties in the contracting chain,” the letter said.





Construction facing safety challenges as work picks up

November 25th, 2013 posted by Jim Stanley

Jim Stanley

The resurgence of the construction industry is, of course, good news, but it  also comes with challenges on the safety front, including shortages of experienced workers and managers.

One indicator of those challenges may be an increase in the construction industry’s fatality rate from 9.1 per 100,000 workers in 2011 to 9.5 in 2012, according to the U.S. Bureau of Labor Statistics. (Although it should also be noted that the 2012 rate was still quite a bit below the pre-recession rate of 11.2 in 2006.)

A recent report by Marsh Risk Consulting cites a shortage of skilled construction workers in markets across the country, including Pittsburgh, Seattle, and Phoenix. Construction job openings increased in June to 133,000, marking a 30% rise over the prior month, the largest percentage change of any industry and the highest number of job opportunities in construction since May 2008.

“The increase in new construction activity is bringing an influx of new, inexperienced workers,” the report says. “In this environment, some contractors are stretching their hiring standards to meet project demands.”

The report goes on to say that in some cases workers are being promoted to management without sufficient preparation, creating another safety concern.

“As the economy grows and the number of new construction projects picks up, now is not the time to be lax on safety,” John Moore, a construction safety specialist in Marsh Risk Consulting’s workforce strategies practice, said in a statement. “Inadequate safety performance can lead to employee turnover and various legal, financial and reputational risks. Investing in high-quality leadership will go a long way toward retaining valued workers and maintaining a safe work environment.”





The real question to ask when an interlock is bypassed

November 4th, 2013 posted by Mike Taubitz

Mike Taubitz

What’s the first question you ask when you find an injury or near miss situation where an interlock or other safeguarding device was bypassed? Do you ask why the employee bypassed the safeguard – or do you ask what is it about the task that required bypassing? This is a subtle but significant difference.

The first approach usually leads to an immediate discussion of the hazards and chastising the employee for the bypass. I’ll explain why that approach is often flawed.

I recently investigated an accident where an interlock into a robot cell had been intentionally defeated. An employee went into the cell to master a fixture and the robot activated, thankfully causing only a minor injury. The maintenance worker who performed the bypass was beside himself with guilt. I asked if the task could be done without power. The answer was, “No.” Mastering the fixture required power, but the cell had been designed to eliminate all power if someone went through the interlocked door.

A combination of using thinking based upon Task Based Risk Assessment (TaBRA) and a rudimentary understanding of machinery opens our eyes to the fact that the cell was improperly designed. If the employees don’t defeat the safeguard, the plant cannot run. How’s that for an eye-opener?

Avoiding the simplistic approach

Just this past week, I returned from another client where we are working on lockout-tagout and using TaBRA. The safety manager went over to a new machine being commissioned by a skilled worker. In this case, the interlock had not been activated to put the machine in a state where there would be no motion. After a few minutes of listening to the exchange, I asked the worker, “Do you need power to do your work?” He looked at me quizzically and replied, “Of course, I’m doing troubleshooting trying to get the machine running.”

There were indeed hazards, but the simplistic approach of thinking a safeguard designed to protect an operator could afford proper protection for this worker doing this task is flawed thinking. Critical thinking involving the worker, engineering and safety is needed to address such a situation.

If you find that your workers are bypassing safeguards and your continued efforts to correct the problem are not yielding results, you might ask, “Does the task you are doing require power?” If not, you have a shortcut and should act accordingly. If the answer is “Yes,” you need to find suitable safeguarding and methods to allow the work to be done safely.





Time for a look at 24-7 safety metrics

October 22nd, 2013 posted by Jim Stanley

Jim Stanley

Our guest blogger today is Mike White, a senior advisor at FDRsafety and recently retired Global Safety Director for GM.

I recently retired as GM’s Global Safety Director and I find myself reflecting upon the ongoing debate in ASSE and other professional forums regarding safety as a value.  In 1994, GM’s top six operating officers created a policy making safety the “over-riding priority” of the corporation.  They did not make safety the #1 priority because they recognized that operations, quality, productivity, etc. must all come into play. However, if there were ever a conflict about providing a safe workplace, decision-makers would err on the side of safety.

Concurrent with assigning direct responsibility to top operations management, this policy and the top management leadership served the company well.  From the outset, GM outperformed every other automotive company.

My reflection, however, is one of mixed emotions. Several years ago, I recognized that moving safety from an “over-riding priority” to “safety is a value” was something that could move us to the next level.  If I were implementing a safety program today, I would strongly recommend having executive leadership commit to “safety is a value” for the company.  When I met Fred Rine, CEO of FDRsafety, I became intrigued with his organization’s 24-7 approach.

Let me share some of my thoughts on why every organization should move to “safety is a 24-7 value.”  In my opinion, those who believe that a “zero-incident” culture is possible without making safety a value will probably be disappointed.  Only when employees understand WIFFM (what’s in it for me) will they be motivated to “want to” be safe.  That won’t come from mandating safety.  Only a positive change in attitude by everyone in the organization can enable actions and behaviors that result in zero incidents.  With only 4% of accidental deaths occurring on the job in this country, why would we believe that getting that 4% to zero is possible or even matters in the overall scheme of things?

Most of us come to work to provide for our family and loved ones.  Would it make any difference if we were seriously or fatally injured on or off the job?  Either way, the family loses a loved one – and the provider.  Moreover, as managers and safety professionals, do we have an off-on switch that we only care about the health and well-being of our employees when they are at work?   I’m guessing that our incessant quest to lower the OSHA recordable rate without having a metric for safety 24-7 is a large part of the problem.  We all know that “what gets measured – gets managed.”

Off-the-job safety efforts are a step in the right direction but those typically play second fiddle to workplace metrics. Perhaps it is time for the profession to devote more energy towards a more holistic approach to metrics and programs that look at the big picture.

 





Manage Safety Risk – Get a “2 Fer”

September 27th, 2013 posted by Jim Stanley

Jim Stanley

Our guest blogger today is Mike White, a new senior advisor for FDRsafety who comes to us after a great career at GM, where he was most recently Global Safety Director.

Let me explain the title and the premise of this blog.  If you manage for risk, you also manage for compliance.  However, if you manage for compliance, you may overlook risk and hazards that result in serious or fatal injuries.

I recently retired from General Motors where I spent the last part of my career as Global Safety Director.  Prior to that position, I was co-director of our joint efforts with the UAW. I spent more than 30 years in operations before going into safety and wondered, “How did I get here?” In both safety positions, I reported to operations executives. It didn’t take me long to appreciate the wisdom of fully integrating safety with daily operations. Thankfully, the groundwork to manage risk within GM and our joint process had been laid.

I’ll share with you my learning and experiences of why managing risk gets you a “2 Fer.” Most safety professionals are aware that OSHA, by mandate, is a violations-based approach. Identification and mitigation of violations is necessary but not sufficient. You must obviously do those things required by OSHA, but that alone will not eliminate injuries, especially those associated with non-routine tasks.

Risk assessment allows workers to assess the exposure to hazards for both routine and non-routine tasks. Let’s say that a maintenance worker is called to fix a machine where parts are not locating properly during machining or assembly. That worker may have to stand in a designated safe place inside an interlocked perimeter guard and observe the machine in full automatic mode.

Upon diagnosing what is thought to be the problem, the worker will identify a pre-task plan to repair the machine in a safe way, lockout the machine and make the necessary repair. Obviously, if there is no safe position from which to observe the machine or perform the task we have a different challenge.You must obviously do those things required by OSHA, but that alone will not eliminate injuries, especially those associated with non-routine tasks.

What happens with a violations-based approach

If you take a purely violations based approach, as OSHA does, it’s typical to find a rule that says, the worker cannot, under any circumstances, be inside the guard with power on. That’s like telling your mechanic that he/she cannot have your automobile engine running to perform diagnostic work. Good luck with that. Workers know when safety rules do not allow them to perform their jobs, and they usually circumvent or ignore the rules to get equipment running.  I’m not talking about shortcuts for expediency. I’m talking about jobs that cannot be performed because our philosophy and designs of machines and guarding emanate from violations-based thinking.

The other benefit of managing risk is enabling the identification of situations that we never see because they could be on off shifts or are in those remote locations where maintenance or other periodic tasks might be performed.  Asking a worker, “If I was a family member who just hired in, what job (whether daily, weekly or annually) might seriously injure me?” You will find that kind of information typically does not show up in our housekeeping or OSHA audits.  Workers don’t have to be experts to understand the fundamentals of risk.

Lastly, traditional safety terms and programs make both workers and executives glaze over.  Risk, on the other hand, is the language of business and the common hinge for all safety programs. Whether safety, business risk, insured risk, market risk, etc., top management understands the fundamentals of risk without a prep course.

In summary, manage risk and get the “2Fer” of managing both risk and compliance.





Hidden hazard in the workplace

August 29th, 2013 posted by Jim Stanley

Jim Stanley

Our guest blogger today is Dan Zarletti, who recently joined FDRsafety as a senior advisor specializing in construction safety, scaffolding and systems safety management.

For more than four decades, safety experts have tried and tested numerous ways to create a workplace culture that strives for zero accidents while improving safety equipment and working conditions. The tireless efforts of thousands of our colleagues and peers have significantly reduced the frequency and severity of workplace incidents and illnesses across all business sectors.

Unfortunately, one “hidden hazard” continues to go little noticed while remaining an underlying cause of work related accidents and material theft. It undermines employee morale and the entire corporate business culture.  It is Substance Abuse!  Even OSHA has remained silent to the extent of relying on the General Duty Clause to cover this social epidemic.

If you still reside in the “State of Denial” over this issue, it’s time to stop worrying about hurting someone’s feelings or infringing on their personal life choices.  You are paying for their expertise and counting on quality work in turn for very substantial compensation.  When it comes to drug abuse in the workplace, the tolerance level must be set at zero.

That means testing, communication and accountability, from those attending employment orientations to the most tenured employee in the company.  And, senior management should lead the way!

It is estimated that a third of our workforce is experimenting with some form of “social” drug while the National Safety Council just announced that “death by accidental overdose of prescription drugs has now surpassed deaths by motor vehicles in America” with more than 42,000 cases reported annually.

It’s time to relocate to the “State of Reality” and expose substance abuse for what it really is; a social and workplace disease.  Users graduate from “Dabbler to Dealer” in a very short time.  Don’t get caught underwriting this “hidden hazard.”





Good News, Bad News: OSHA and the Global Harmonization System

August 22nd, 2013 posted by Jim Stanley

Jim Stanley

Our guest blogger is Joe Wolfsberger, a senior advisor at FDRsafety and an expert in occupational health/industrial hygiene.

OSHA has published the final rule on the Global Harmonization System that applies to producers, distributors and users of chemicals.  This revision to the existing Hazard Communication Standard has implications that are both positive and negative.  Let’s take a look at the good news / bad news and how it will affect you and your operations.

The good news

For companies with a global presence, the promise of universal regulations is seen as welcome relief from the multitude of regulations that they must deal with around the world.  While a single set of EHS regulations that apply for all countries is still only a distant future hope, steps are being taken to harmonize the chemical hazard information requirements across much of the globe.

In an effort to support this, OSHA on March 26, 2012, published the final rule for its Global Harmonization System regulations.  A summary of the regulation can be found here. As with any new regulation there will required changes to the way companies comply. Material Safety Data Sheets (MSDS) will become Safety Data Sheets (SDS) requiring 16 specific sections ensuring consistency with other countries’ regulations, and labels must include a signal word, pictogram, hazard statement and precautionary statements for each hazard class and category.  All of this is designed to enhance worker comprehension of hazards and eliminate confusion.

Now, the bad news

The changes being made to integrate GHS into the HazCom Standard will alter the way flammables are classified, making them no longer consistent with NFPA’s categories for flammables.

OSHA will no longer have a classification of combustible; all liquids with a flashpoint below 199.4oF (93oC) will be referred to as flammable. (Note: the Mine Safety and Health Administration has not changed their definitions)  OSHA will be changing from three classes with sub classes (Class I A, I B, I C, II, III A, & IIIB) to four categories (Category 1, 2, 3 & 4).  Classification will still be based on the flashpoint of the liquid but the ranges will be different.  There is not a one-to-one relationship between classes to categories as can be seen in the following chart.

FDR CHART PNG REsized

Although OSHA has changed its classifications, many states and municipalities have adopted NFPA and International Fire Codes (IFC) as the basis for their local ordinances on flammable liquids.  Care must be taken to ensure that complying with the new OSHA regulation does not create a non-compliance situation with local ordinances.

As an additional note, although the implementation date for product manufacturers is June 1, 2015, and for distributors December 1, 2015, workers must receive training by December 1 of this year.  Training must include the new label elements and safety data sheet format in addition to the current training requirements.

For information on training requirements for GHS, see our earlier post. If you have any questions about the OSHA Final Rule on Hazard Communication, classification of flammable liquids, hazard assessments, OSHA Compliance Inspections or health and safety training, contact us at info@fdrsafety.com

 

 





Training deadline approaching for Globally Harmonized System

July 26th, 2013 posted by Jim Stanley

Jim Stanley

Our guest blogger today is Jim Carnahan, a member of the FDRsafety team specializing in advising clients on compliance with new OSHA regulations on Globally Harmonized Systems.

December 1 is the first deadline under OSHA’s new Globally Harmonized System regulation, which requires that employees be trained on the new label elements for chemicals and the new Safety Data Sheet (SDSs) format. Full compliance with the other elements is to begin in 2015.

OSHA requires this training by December 1 because workplaces will soon begin to receive new labels and SDSs, in keeping with the new GHS regulation.

Employees will need to be trained on new GHS label elements that include:

  • Symbols (GHS Hazard Pictograms): Assigned to each hazard class and category. Conveys health, physical and environmental hazard information
  • Signal Words: “Danger” and “Warning” to emphasize hazards and also indicate the severity level of the hazard
  • Hazard Statement: A standard phrase assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including where appropriate, the degree of the hazard.
  • Additional label requirements: Includes Precautionary Statements, Product Identifier, Supplier Identification and Supplemental Information.

Employees must also be trained on the new Safety Data Sheets. The SDSs are similar to the current MSDSs except the “M” (Material) has been dropped.

  • The information required on the SDS is relatively the same as the current MSDS, but the information in the SDS must be presented using specific headings in a specified sequence.
  • The GHS rules requires information to be listed under 16 specific headings.

Additional information on the new GHS regulation, including the training requirements:

  • OSHA Fact Sheet – “December 1, 2013 Training Requirements for the Revised Hazard Communication  Standard”
  • Questions and Answers regarding the new GHS regulation on the OSHA website

Please note that some manufacturers have already upgraded their chemical labeling and Safety Data Sheets and may be shipping these containers to your facility. Therefore, completing this training sooner would be beneficial to minimize any confusion your employees may have when they encounter these new labels or read the new SDSs.

If you have any additional questions, please contact  Jim Carnahan at info@fdrsafety.com.