OSHA shines spotlight on metal fabricating
By knowing the agency’s focus areas, fab shops can stay out of trouble—and keep workers safe
For the sake of maintaining a safe work environment and keeping the Occupational Safety and Health Administration’s investigators out of business operations, metal fabricators should be aware of the areas where they can improve their own safety performance. OSHA’s citations provide a guide to where the focus should go.
Last year citations from the Occupational Safety and Health Administration (OSHA) cost metal fabricating businesses more than $7 million. The actual cost of these violations is much higher, however, because it does not include other direct or indirect costs such as damaged facilities or equipment, medical costs, replacement personnel, and increased workers’ compensation.
Avoiding these costly OSHA citations requires that metal fabricators provide a safe workplace and understand what OSHA might focus on in their business. Looking at 2013’s most frequent and costly OSHA citations (see Figure 1) can give company owners and management insight on where to focus compliance efforts.
1. Machine Guarding and Safe Equipment Use
Machine guarding and safe equipment use took front and center stage, costing the industry nearly $3 million. Moving machine parts have the potential to cause severe workplace injuries, such as crushed fingers or hands, amputations, burns, and blindness. Safeguards are essential for protecting workers from these preventable injuries. Any machine part, function, or process that may cause injury must be safeguarded.
Primary violations centered on basic issues such as the provision of guards that meet OSHA’s requirements for design and construction. Lockout/tagout violations were the second most frequent citation (see Figure 2). Safety violations related to the use of mechanical power presses, abrasive wheel machinery, hand and portable powered tools and equipment, mechanical power-transmission apparatus, and woodworking machinery accounted for the rest of the citations.
The safe condition and use of all equipment, including that furnished by employees, is the employer’s responsibility. It is critical that employers be aware of the OSHA regulations that pertain to the specifications, use, and maintenance requirements of their tools and equipment.
Electrical hazards were the second most frequently cited area, costing the industry more than $750,000. An average of one worker dies from electrocution on the job every day. Even low voltage or low current can cause serious harm or death.Violations in this area included improper grounding, extension cord safety, guarding, lockout/tagout issues, and wiring design and protection. Those at primary risk are employees who use electric-powered tools and equipment and anyone who is responsible for handling electrical issues.
Employers also were cited for insufficient employee training.
3. Material Handling
Use of material handling equipment was another costly citation area, totaling well over $500,000. Citations included violations in the use of powered industrial trucks, overhead and gantry cranes, and slings.
It is essential that employees have the training and knowledge to use material handling equipment properly and that safe work practices are established at the fabrication facility.
4. Personal Protective Equipment (PPE)
This emphasis area cost the industry almost $500,000. Each employer must determine what protective equipment is necessary for each employee and each task. Even when the employee furnishes his or her own protective equipment, the employer is responsible for ensuring its adequacy on an ongoing basis. Citations were issued, in order of frequency, on the following:
- Respiratory protection. Respirators may be needed for protection from airborne chemicals, such as hexavalent chromium (see Figure 3); toxic gases or mists; inhaling grit or dust, such as silica when sandblasting; and metal fumes produced by welding. Exposure must be determined for each chemical, and the respirator’s protection level must be adequate for the exposure. Before an employee uses a respirator, a physician must determine that it is safe to use, and then the employee must be trained on its use and care. The respirator program must be documented in writing.
- General requirements. These include proper selection and provision of equipment, adequately written programs, training, and use and care of PPE.
- Eye and face protection. Metal fabricators typically need eye and face protection from flying particles, molten metal, liquid chemicals, chemical gases or vapors, harmful light radiation, and infectious materials. Full face shields may also be needed to protect their face from these hazards.
- Hand protection. Several types of gloves obviously are used in the metal fabricating industry. Special gloves are required for welding, and various types of protective gloves prevent injury from sharp edges and heat. Special gloves also may be needed to protect skin from chemical hazards, such as paints, solvents, hexavalent chromium, and cleaning fluids. The correct glove selection is based on the type of hazard present, the needs of the job, and the duration of use.
- Head protection. A protective helmet is required for employees who could hit their head or who work in an environment where something could fall on them. Employers must provide the correct hard hat for each employee depending on the needs of the job. Some helmets reduce the force of a blow only to the top of the head, while others reduce the force of a blow from both the side and top. In some cases, protective helmets that are designed to reduce electrical shock hazard may be required.
- Foot protection. Most individuals working in a metal fabricating shop need foot protection. Depending on the specific hazards of each job, protection may be needed from falling or rolling objects, sharp objects, exposure to electrical hazards, and exposure to chemicals or water.
5. Toxic and Hazardous Substances
Far and away the most frequent and costly violation in this area was hexavalent chromium safety, representing more than half of the citations in this category and over $250,000 in fines. Other citations issued, in order of frequency, were for lead, airborne contaminants, asbestos, inorganic arsenic, cadmium, anhydrous ammonia, acetylene, formaldehyde, and methylene chloride.
OSHA has regulations and specific safety requirements for each of these hazardous substances.
6. Walking/Working Surfaces
These citations were violations for guarding floor and wall openings; walking and working surfaces; scaffolding and ladders; aerial lifts; and vehicle-mounted elevated and rotating work platforms.
7. Fire Protection and Emergency Planning
Citations in this area covered portable fire extinguishers; emergency action plans; automatic sprinklers and other fire protection and prevention systems; configuration of exit routes; medical services and first aid; sanitation; and accident prevention signs and tags.
OSHA regulations clearly spell out requirements for emergency preparedness and the provision of a safe work environment. The key is to understand these regulations and, obviously, to meet the requirements.
8. Hazard Communication
Every year hazard communication is near the top of the list for all industries, and 2013-2014 was no exception. If a manufacturer uses even a single hazardous chemical, it needs an Employee Right-to-Know program in place. In 2012 OSHA updated the Hazard Communication Standard by adopting the Global Harmonized System (GHS) of Classification and Labeling of Chemicals. GHS is an internationally agreed upon system that replaces the various classification and labeling standards used in different countries. The revised standard includes important changes to classification of chemicals, the material safety data sheet format (now called safety data sheets, or SDS), and labels for chemicals. A company’s Hazard Communication Program must be in writing. Manufacturers also should be aware of upcoming deadlines for compliance with this revised standard.
The deadline for employee training on new label elements and SDS format was Dec. 1, 2013. The deadline for full compliance with the new Hazard Communication Standard is June 1, 2016.
9. General Duty Clause
The OSHA General Duty Clause is the catch-all standard that states the employer must provide an environment “free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees.” Hazards must be identified before employees are exposed and preventive precautions taken. Employees must be trained on these hazards and how to work safely. Examples of these violations include ergonomics, burns, working in hot or cold environments, and any safety issue that is not specifically addressed in a regulation.
10. Welding, Cutting, and Brazing
Welding, cutting, and brazing are exceptionally dangerous. Welding creates fumes, radiation, and other hazards. OSHA has a full set of regulations detailing safe work practices and procedures. The standard covers operating within a safe work environment and with detailed work procedures, equipment maintenance, and safe storage of gases and supplies when not in use. It also details safety procedures for each type of welding. It focuses on fire protection, PPE, and health protection and ventilation.
The first step in avoiding OSHA citations is to understand what OSHA requires. Then metal fabricators must develop safety programs accordingly and train employees so that they understand their hazards and what they must do to protect themselves. Developing a safety program may seem like a daunting and expensive task, but studies have shown a $4 to $6 return on every $1 spent on safety and health.
The FABRICATOR is North America's leading magazine for the metal forming and fabricating industry. The magazine delivers the news, technical articles, and case histories that enable fabricators to do their jobs more efficiently. The FABRICATOR has served the industry since 1971.