These 10 basic safety tips not only will prevent injuries, but can make inspections less painful and might even save you money.
By Joe Glowaski
Joe Glowaski is the Director of Operations Development at Atlantic Precast Concrete Inc. in Tullytown, Pa., and serves on the NPCA Board of Directors.
Safety in the precast concrete industry, or any industry, has become a difficult balancing act. The conflicting demands of the U.S. OSHA, workers’ compensation insurance and being productive seem to battle each other constantly. Insurance reporting often conflicts with OSHA reporting; an OSHA inspection is more demanding than an insurance loss control visit. It is difficult to see where your company stands with all of these demands. By the way, you still need to manufacture a product and make a profit.
Where does a company start? Who should take care of all of these demands? Who’s going to pay for all of this? Unfortunately, there is no one magic program that can put this all in line. However, there are 10 basic safety-related topics that, if addressed properly, can prevent injuries, make OSHA inspections less painful and, ultimately, keep the company from losing money.
This list may not steer your company clear of 100 percent of the problems you may encounter, but it will help to establish a safety culture, aid in meeting the most commonly addressed OSHA regulations and help create a more profitable business by keeping losses at a minimum.
Safety or loss prevention, like any other business decision, must have 100 percent buy-in from everyone, including the owner as well as the newest employee. By defining clear goals – “We will implement a complete Lockout/Tagout Program by June 2006” or “Our goal is a 20 percent reduction in workers’ compensation claims” – everyone can see where the company is going with safety and why. Make safety a key element in the company’s Strategic Business Plan, and safety will become an integral part of the business.
Leadership and management skills are critical to making the commitment. Safety is truly everyone’s responsibility, and everyone should have some accountability for it. Senior management should be evaluated for safety responsibilities along with their production and sales goals. Accountants, production schedulers and even sales all play a role in safety and loss prevention through purchasing safe products, scheduling acceptable work loads and selling products that meet safety standards. Their responsibilities need to be established, and they must be evaluated accordingly.
Safety must be a core business competency, not simply a priority. Priorities change, but as a core value, safety will always remain important. If your company is not quite ready to make this type of commitment, you would do well to at least try to implement some of these topics.
2. OSHA logs
The first items an OSHA compliance officer will ask for during any inspection are the OSHA 300 and 300a logs – usually at least three years’ worth. These are the records of all recordable injuries for a given year, and they give the compliance office an instant snapshot of the company. The logs are not difficult to keep, but they must be kept up to date and accurate.
Having accurate OSHA 300 logs can do many things for the company. First, the logs are required by law in the OSHA standards – having them will keep you from being cited and possibly fined.
Secondly, keeping the logs as well as accurate “hours worked” reports can actually prevent your facility from being inspected. OSHA often develops inspection directives on who it will inspect during any given year. The directives are established by comparing a company’s injury rates to the national average for the injury. If an inspection were scheduled as a result of the industry’s incident rate, the OSHA logs can show the compliance officer that the company’s rates are below the industry average and an inspection is not warranted. It is not a complete guarantee, but it usually works that way.
Lastly, keeping the logs is a sign to the compliance officer that the company takes compliance seriously. If you can instantly produce the logs for an inspector, the inspector may feel that your company is in line. If there is confusion about the logs or they are nonexistent, the compliance officer is more likely to think you are hiding something, and an inspection will be conducted.
Keeping the required OSHA logs is an easy and very beneficial task to perform. Anyone can do it, but it usually belongs to the department responsible for human resources, since it is the one typically responsible for managing workers’ compensation issues.
3. Hazard communication (right to know)
The next item a compliance officer will ask for is the company’s Hazard Communication Program. The program must contain, at a minimum, a written policy, a training component and the company’s Material Safety Data Sheets (MSDSs). This is one of the most frequently cited OSHA violations, but it is one of the easiest to comply with.
The written program is pretty much a standard program that needs little customization (available to all NPCA members at no cost in the NPCA Plant Safety Manual). It basically states how the program is to be managed, how employees are to be trained and how hazardous materials are to be labeled.
The training component is rather easy to comply with as well. As long as employees’ jobs or chemicals they work with do not change, this training is required to be done only once upon initial hire. Of course, it is always a good idea to do periodic refreshers to promote safety and remind workers of the hazards present in the workplace. This training must be done before the employee begins work.
Finally, the MSDS files must be maintained. Every item considered to be a chemical, mixture of chemicals or any material that is altered in any way by the employer (including raw materials) must have an MSDS. Items that are deemed to be articles, such as rubber gaskets, do not need to have an MSDS.
The MSDSs must be kept in such a way that they are easy to find. Alphabetical order usually works best. They must also be available to employees at any time during their work shifts. If a trip to the doctor becomes necessary due to exposure to a chemical, it is also a good idea to send any MSDS along with the employee.
4. Lockout/Tagout – Energy Control Program
The most significant program a company can have is an effective Energy Control (Lockout/Tagout) Program. This program is designed to develop the training, procedures and recordkeeping to keep employees safe while working on or around equipment and materials where an accidental startup could result in the release of energy, such as mechanical, electrical or chemical. The unexpected energy release usually results in severe injuries or fatalities.
The first thing to do is develop a written program. It must contain a copy of the standard, how training will be conducted, how and where a lockout/tagout must be performed, the limitations of a tagout and the step-by-step procedures for how each piece of equipment is to be locked or tagged out.
Once you develop the program, you must conduct training. Training must be done on an annual basis, unless there has been a change in equipment or procedure or if an employee demonstrates a lack of knowledge at any time. You must also conduct and document an annual audit of the authorized employee’s performance.
Also conduct training for those who are not authorized to perform a lockout. All employees need to be aware of the necessity and requirements of this program to ensure that others are not injured. As with any safety program, documentation is critical.
The Energy Control Program has been a special emphasis program for OSHA. This means that OSHA can target any industry for inspection.
It is a good idea to have a second set of eyes look at your facility, such as an insurance company, a consultant or even the NPCA Safety Committee.
5. Powered industrial trucks
Powered industrial trucks, lift trucks and other such machinery can be a significant hazard in our workplaces if not properly controlled. Therefore, operator training is critical. All operators must take a written test to demonstrate that they are aware of the general safety and operating procedures for powered industrial trucks. In addition to the written test, they must also be qualified and tested on each piece of equipment they may operate. Just because they pass the test on a 10,000-pound lift truck does not qualify them to operate a 20,000-pound machine as well. Training must be conducted every three years, at a minimum. Retraining is required whenever there is a change in the equipment, in an employee’s responsibilities or if the employee has demonstrated a lack of proficiency, such as being involved in an accident or speeding.
Maintenance, inspections and documentation are also critical to the success of the program. The best-trained employee can easily be in danger if the equipment is in poor operating condition. Pre-operation inspections, mechanic inspections and repair logs must all be maintained. This not only will ensure compliance with the standard, but it will also be vital evidence in case of an accident.
6. Crane safety
Along with the powered industrial trucks, cranes are an integral part of the precast industry. The crane standards are in a bit of a transition, but there are many basic actions you must take regardless of what types of cranes you are using.
Training, once again, is critical. There is a major push to require all overhead crane operators be licensed by a third party. This is already true with other types of cranes. Inspection procedures, operations, and rigging and loading would all be a party of the licensing procedure. Regardless of whether it is required, employers should still train to this standard.
Equipment maintenance is of the utmost importance. Annual, frequent (monthly) and daily inspections are all required under the OSHA standards. Annual inspections are often performed by an outside agency to give a complete picture of the crane’s condition. Monthly inspections can be done in-house by trained maintenance personnel, and daily visual inspections must be performed by the operator at the beginning of each shift. Documentation is critical once again.
Employers often look only at their overhead cranes when complying with this standard, but it is important to remember that hoists and truck- and trailer-mounted cranes also can fall in this standard. Even when there is a gray area in the standard, an employer can be cited under the general duty clause for having an unsafe condition.
7. Hearing conservation
The hazards associated with equipment, products and facilities are easily recognized by the industry, but when it comes to issues of industrial hygiene, they are often overlooked. Such is the case with noise exposure.
Noise is all around a facility, from the equipment and formwork to the stereos in the shops. It all adds up to what can be a rather noisy environment. But what is a “noisy” environment? The only way to know for sure is to perform a noise exposure survey. This can be done by an industrial hygienist, and a company’s insurance company can usually set this up. For this survey, the hygienist will measure the amount of noise that a representative employee is exposed to during a normal shift, then compare that exposure to the values under the OSHA standards.
Currently an employee cannot be exposed to more than a time-weighted average of 90 decibels during a shift without ever exceeding an impact of 140 decibels at any time. If the standards are exceeded, the employee must partake in a hearing conservation program.
This consists of annual hearing tests, training, hearing protection and possibly work rotation to control exposure during the shift. Additionally, if the employee is exposed to a time-weighted average of 85 decibels, monitoring becomes necessary as well.
A better way to manage this is to make the work environment quiet by using dead-blow hammers, self-consolidating concrete to eliminate the noise generated by vibration, and air line maintenance to eliminate the leaks that emit high-pitched noise throughout the facility.
8. Personal protective equipment
What personal protective equipment is required in a precast facility? It all depends on the facility. That is why a workplace assessment is necessary. The assessment looks at all of the operations to see what hazards are present, then determines what type of equipment could protect an employee. The assessment can also show that personal protective equipment is not necessary in certain areas. Equipment can range from hard hats and safety glasses to respirators and chemical protective clothing.
Hard hats, steel-toed boots and safety glasses are considered to be the accepted minimum. They will help to protect from the basic hazards in most precast facilities. If a respirator is required, it calls for a more sophisticated and specific program that includes training, medical qualification and fit testing. There is a large range of personal protective issues, but if a company starts with the basics and involves employees in the equipment selection process, the implementation of the use of the equipment will be smoother.
9. Accident and injury reporting
Sometimes even with the best loss-prevention efforts, accidents and injuries will occur. When they do, a company must be prepared to act immediately. With every delay in reporting or action, the cost of even a seemingly small injury can skyrocket.
Under OSHA standards, a company is required to have an accident and injury reporting policy. It must include how an injury is to be reported, who it is to be reported to and, of course, documented training on the procedure.
Fortunately, a company’s workers’ compensation carrier is usually strict about this process and can set up the program for the company. Having a plan for this and any other situation will help an organization control the situation and thus control the loss associated with an injury. Planning, preparation and education are the keys in developing a safe work environment at any level.
10. OSHA compliance officer visit
It may not happen today or tomorrow, but it will happen someday, and at the most inconvenient time possible – the OSHA inspection. If a company has the basics in line and is prepared to manage an inspection, it can actually be a positive experience.
The key to managing the situation is knowing what a company’s rights are during an inspection. They are all listed in the OSHA standard. A procedure should be written to ensure that the inspection is managed correctly according to the law and that everyone from the receptionist to the president of the company is aware of their roles and responsibilities during the inspection. The location of OSHA 300 logs, training records and safety policies should be known to all.
Provisions should be made to ensure that a compliance officer’s credentials are valid, that an opening and closing conference is held and that a company representative mirrors the actions of the inspector during the walk-through. The representative should take the same photos and notes as the inspector and work to immediately eliminate any hazards that the inspector mentions.
There is a bit more to the whole procedure than that mentioned here, however. An attorney may be able to help with the legal aspects of the procedure. The key is that through preparation, even the most difficult situation can be managed.
Following these 10 recommendations is no guarantee of complete compliance with OSHA standards or the creation of an accident-free facility, but they are a great starting point. Fortunately, you need only have the will and commitment to make safety a core business competency to create a safety culture.
All of the safety programs mentioned in this article are available in the NPCA Guide to Plant Safety. The guide also includes all of the training materials in English and Spanish.
In the 21st century, there is no reason for anyone in the precast industry to not be in compliance with the basics of safety and loss prevention. All precasters must do what they can to protect their employees and their assets to ensure the successful future and growth of their businesses. Safety and planned loss prevention are the easiest, most cost-effective and measurable ways to do this.