March 13, 2007
Assessing the work environment, creating programs, and training staff to abide by those programs are the keys to maintaining a safe work environment and avoiding steep fines, worker injury, or death.
Last year the Occupational Safety and Health Administration (OSHA) issued more than $750,000 in citations to the metal fabrication industry for equipment-related safety violations. This includes tool usage and guarding issues, control of hazardous energy (lockout/tagout), and electrical safety. These citations do not begin to account for the total cost to metal fabricating shops when considering associated property damage, medical costs, workers' compensation and insurance increases, lost work time, and lawsuits that often go along with the citations. To avoid equipment-related incidents, you must understand OSHA requirements and have safety programs in place, including those pertaining to tool safety and machine guarding, lockout/tagout, and electricity.
Safe tool usage and machine guarding violations were the most frequent and costly citation areas last year. The first thing that you must do is assess the specific hazards by evaluating each piece of equipment. If the machine is new, determine all points of operation, pinch points, and areas that require protection. Ensure that all required guards are in place, and replace any missing guards before allowing anyone to use the equipment.
If you have an older machine that needs guards, you must first determine if the machine is still made. If it is, contact the manufacturer and ask for information on the current guards supplied with new machines. Purchase or replicate the new guard configurations to provide protection, and discard any equipment that cannot be guarded adequately.
After you have assessed the hazards and have adequate guards on your equipment, you can then develop your safety program. Equipment operators must leave the guards on at all times unless the equipment is locked out. Include in your safety program your policy on removal of guards, including who is authorized to do it, and the required lockout/tagout procedures. Also include discipline for employees who remove or bypass guards.
Next, explain the function and purpose of the guards to each employee. Managers and employees must be familiar with the proper guards so they can recognize when something is missing. Without knowledge of the safety program and the purpose and function of the guards that protect them, employees are more likely to bypass or remove them. Remember that a successful training program is always time and money well spent; studies have shown a $4 to $6 return for every dollar invested in safety and health.
Failure to follow safe lockout/tagout procedures also accounted for a significant percentage of citation dollars. An effective lockout/tagout program is especially critical because the type of accident it is meant to prevent typically is severe and can result in crushing, amputation, struck-by, or electrocution injuries. OSHA requires you to identify the practices and procedures necessary to shut down and lock out or tag out machines and equipment; provide locks; and train employees on their role in the lockout/tagout program. Also, conduct periodic inspections to maintain or enhance your hazardous energy control program. The No. 1 citation in this area is lack of an effective written program.
Assess hazards by first identifying the lockout requirements for each piece of equipment used, serviced, and maintained at your facility. All energy sources must be documented, including direct and hidden sources. Documentation must include the hazard posed, the magnitude of danger, any special or unusual conditions, and the correct isolation methods and required devices.
About 95 percent of all lockout/tagout citations involve companies' failure to have a formal program in place. The energy control or lockout/tagout program must be written and must include your hazard assessment, devices to be used, personnel authorized to perform lockout/tagout, enforcement policy and training methods, and the method for auditing and updating procedures. You must develop written procedures for shutting down and locking out each machine. Except in emergencies, each lock/tag must be removed by the person who put it on, and each employee must have his or her own locks and tags. Make sure your written program accounts for situations when servicing lasts longer than one shift, when contractors are involved, or when a group of employees services a piece of equipment.
The training program must consist of effective initial training and periodic retraining. You must have certification that training has been given to all employees covered by the standard. The training each employee needs is based on the relationship of his or her job to the machine or equipment being locked or tagged out. OSHA identifies three types of employees: authorized, affected, and other.
Retraining must be provided whenever there is a change in job assignments, machines, equipment, or processes that present a new hazard; when there is a change in energy control procedures; inadequacies are present in employees' use of the energy control procedure; or at least every three years.
Periodic inspections must be performed annually on each energy control procedure at your site, and the employer must certify that the periodic inspections have been performed. The certification must identify the particular machine, the date of the inspection, the employees included in the inspection, and the name of the person performing the inspection.
An average of one worker dies from electrocution on the job every day. Even low-voltage or low-current shock can cause serious harm or death. All of the equipment in a metal fabricating shop operates on 110 V or more and is capable of causing electric shock, burns, or electrocution.
Check your tools and equipment to ensure that the ground prong is present and that cords are in good condition. OSHA requires that live parts of electrical equipment operating at 50 V or more be guarded against accidental contact. Whenever conduit or electrical equipment is in a location where it could be exposed to physical damage, it must be enclosed or guarded. Junction boxes, pull boxes, and fittings must have approved covers. Unused openings in cabinets, boxes, and fittings must be closed.
Flexible cords are vulnerable because they can be damaged by aging, door or window edge contact, staples or fastenings used to hold them in place, abrasion from adjacent materials that they may contact, and various activities in their proximity. Improper use of flexible cords or use of damaged cords can cause shocks, burns, or fire. Whenever possible, use one of OSHA's recognized hard-wiring methods. OSHA allows flexible cords to be used only for certain applications.
Check your circuits regularly. An inexpensive tester can tell you if the ground is connected and can also test your ground fault interrupter (GFI) protection. Your safety program must include policies for grounding systems and electrical shutoff device systems. Develop policies for use of ladders and scaffolding around electrical devices. Extension cords have specific current ratings that must not be exceeded or they can overheat and cause a fire without tripping the circuit breaker. Use a qualified electrician for installation and repair of circuits.
Personnel who are at primary risk of electrical hazards are arc welders, those who work with or around electric power tools and equipment, and maintenance and janitorial staff who are responsible for handling electrical issues at your facility. At lesser risk are all other personnel who work with or around other electrical equipment, including lighting, computers, coffee makers, and so forth. Training must be adequate to the needs of each employee depending on his or her specific tasks.
Employees must understand the built-in safety features of electrical systems, including insulation, ground fault circuit interrupters, double-insulated devices, grounding (both of the circuit and the equipment), guarding of live electrical parts, and fuses and circuit breakers.
Employees also must follow safe work practices, such as de-energizing electrical equipment before inspecting or making repairs, correct usage of flexible cords and extension cords, recognition of damaged electric tools and procedures to remove them from use, how to work safely near energized lines, and use of personal protective equipment.
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