A wealth of the “same old” classic hazards have not been properly dealt with in the heat treat industry. It is critical to address these basic (often severe) risks/violations rather than simply trying to identify new-to-the-forefront issues.
Please note that this list is surely not all-inclusive. I’ll make this concise.
Let’s take a look:
- Are you still allowing impediments to immediate access to exits, fire extinguishers, electrical disconnects, and emergency eye fountains?
- Are you permitting unguarded (or improperly guarded) power transmission equipment, highlighted by chain drives, belt drives, couplings, and gears?
- Have you adequately guarded fan blades?
- How about the (chemical) hazard communication program— especially the labeling, safety data sheets, and training? [Don’t forget the Globally Harmonized System.]
- Is the lockout/tagout program, relating to unexpected energization and release of stored energy, sufficient— attaining ZES (zero energy state addressing electrical, mechanical, pneumatic, hydraulic, spring, thermal, steam, gravity+), only one “available” key per personal lock, machine-specific procedures, and more?
- What kind of permit-required confined space program have you implemented— a detailed, super priority tackling matters of oxygen deficiency, vapor ignition, entrapment, and so on, with a fully integrated plan including (but not limited to) space identification, permit system, calibrated instrumentation, attendants, non-exposed rescuers?
All set now? WAIT! There’s more that is routinely violated on a regular basis. These items above, and to follow, are not simply a matter of technical non-compliance with the law of the land; they are scenarios waiting to ambush workers and leave them with burns or worse (from fire, explosion, and electrical sources), mangled digits and limbs, blindness, lung damage… and many other examples of preventable misery.
Abatement can be motivated by a desire to avoid “breaking the law and paying the price.” It can be motivated by ethics and the sincere “touchy feely” desire to “do the right thing.” Yet, it can also be motivated by a company’s knowledge that employee protection is good business, in very tangible, financial terms. The cost of occupational injuries and illnesses can decimate your profit line via far more than direct medical costs. Please consider all of the follow-up medical bills, cleanup, overtime, downtime, insurance rate increase, and much, much more. Then there are the enhanced OSHA penalties.
Pardon the diversion. Now for a look at some more key questions:
- Is heat stress considered to be a very real concern (and met head-on as an occupational hazard), rather than viewed as a mere matter of degrees of comfort?
- Has there been a full assessment of personal protective equipment needs?
- Is safety-toed footwear required, as determined by such an assessment?
- How about eye protection (consider different forms for different hazards), hand protection (again, particular types for particular risks), hearing protection, flame-resistant/retardant clothing, and… whatever else is brought to light by way of a thorough assessment considering each task to be performed?
- Are the extinguishers conspicuous, fully charged, and professionally tested on a timely basis?
- Who is expected to use the extinguishers, and have those employees been “hands-on” trained?
- Are compressed gas cylinders well-secured, capped (where designed to be), and properly separated (oxygen from fuel gas, in storage)?
Have I offered enough tips? No? OK. Here are just a few more points to ponder:
- Are electrical cords in good condition, without (for instance) stripped/cut/burned insulation, damaged/missing grounding prongs, or similar damage? [Remember that portable electrical tools can be double-insulated, as an alternative to grounding.]
- Is there accurate, unambiguous, easy-to-read labeling on disconnects, breakers, controls, and so on?
- If there are breaker slots without breakers, are those spaces filled with blanks?
- Are electrical boxes and similar apparatus equipped with approved covers?
- Are forklift trucks, and similar vehicles, properly maintained, with emphasis on steering, brakes, horn, tires, overhead guard, and fork movement reliability, and are all operators suitably trained?
- How about the elimination or deep mitigation of trip and slip hazards?
- What have you done, including by engineering means and specific training, to decrease exposure to ergonomic hazards, especially regarding backs?
Article provided by Rick Kaletsky, MTI’s Official OSHA Safety Consultant. If you would like to speak with Rick on safety issues in your plant, feel free to contact him at 203-393-1233 or rkaletsky@gmail.com.