A strong and successful safety program consists of many key elements, including the identification and assessment of potential hazards preventing, controlling those hazards and continually evaluating and improving your safety program.
But how can precast concrete facility supervisors know that they have correctly identified the most potentially dangerous hazards or even which ones are harder to mitigate, require more attention and necessitate training?]
Looking inward provides only part of the solution. Safety managers evaluate the effectiveness of safety plans and learn from mistakes, but that is a reactive approach. The primary goal of every good safety plan is to minimize mistakes.
While safety violations are regrettable and can be costly to those who make them, mistakes made by others are valuable for helping find weaknesses in any plan, which is why the Occupational Safety and Health Administration (OSHA) has provided a list of its most frequently cited standards.
Frequently cited OSHA standards
Fall protection, respiratory protection and ladder safety are the three most cited OSHA standards across all industries. More specific information is available for industries that have been given a North American Industry Classification System (NAICS) code by OSHA. The code that is most relevant to precasters is NAICS code No. 3273 for Cement and Concrete Product Manufacturing.
In this specific category, the most cited OSHA standards are:
- Control of hazardous energy (lock out/tag out)
- Respiratory protection.
- Hazard communication.
Lock out/tag out
A considerable amount of heavy equipment is required to weigh, mix, convey, pour and transport concrete throughout the manufacturing process. Before equipment can be serviced or maintained, it is imperative that a lock out/tag out (LOTO) procedure be developed and implemented for each machine in the manufacturing process.
“You need to have machine-specific lockout/tagout procedures,” Curt Moore of Fisher Phillips said. “Employers should have a detailed, written procedure informing employees of every source of hazardous energy that needs to be isolated on the equipment to get it to a zero-energy state.”
Every authorized employee expected to work on the equipment must, therefore, be trained on the machine-specific LOTO procedure. Affected employees should be given the appropriate LOTO training as well.
In addition, all LOTO actions must be randomly verified on a routine basis. Individual LOTO processes must be audited while they are in use and documented, recording which machine or process was audited, which personnel were involved in the LOTO procedure, the time at which the audit was conducted and any corrective actions that may have been made.
Additionally, an audit of both documentation and implementation of the energy control program for an entire facility must be conducted and documented at least annually.
When it comes to maintaining equipment logs, such as a mixer that is locked out every day for cleaning, Jason Brewster of Atlantic TNG LLC looks to technology.
“We went to making logs on our phones through an app, and that’s made it a lot easier because those records are automatically uploaded to the cloud, and you don’t have to worry about losing them,” he said. “We also place checklists on the app to help employees check through what they need to do and make sure it’s done right.”
OSHA’s General Respiratory Protection Standard 1910.134 covers respirators, fit testing, medical evaluations and more, but, generally, respiratory protection in the concrete industry primarily refers to exposures to respirable crystalline silica caused by grinding or cutting concrete.
Engineering controls such as using water or a HEPA vacuum system to control dust while cutting are the most effective first line of defense against silica exposure, followed by good workplace practices such as thoughtful housekeeping. If neither of those approaches are sufficient to keep exposure levels below the current threshold of 25 μg/m³ within an eight-hour workday, then personal protective equipment (PPE), such as dust masks or respirators, must be used.
Even when PPE is provided, violations can occur when masks are not properly fitted to each individual employee or not checked for operation and adequate capacity prior to use.
“Make sure your PPE for respiratory protection is being checked,” Brewster said. “If filters are not being replaced when they need to be, then it’s not really protecting them.”
Exposure levels must be reassessed every time there is a change in equipment, processes or work practice that could result in exposure levels above the action level. For exposure levels that require masks, OSHA Rule 1926.1053 must be followed.
NPCA provides numerous resources for help in meeting OSHA’s compliance standards, including the Occupational Health Program & Written Exposure Control Plan for Respirable Crystalline Silica, available free to all NPCA members.
In addition to silica exposure, other respiratory hazards, such as carbon monoxide buildup, also may need to be addressed. For instance, a separate respiratory hazard analysis may be required for an enclosed heated workspace such as the interior of a curing kiln.
Similar to silica exposure, hazardous carbon monoxide levels could either be addressed through engineering controls such as improving ventilation, improving heating efficiency or through the use of PPE such as a properly fitted respirator.
The third highest citation on the list, hazard communication, can occur when using secondary containers that contain hazardous chemicals poured from a larger drum or original container. OSHA’s Hazard Communication Standard (HCS) has specific requirements for labeling that cannot be shortened or neglected.
Hazards must be properly classified and standard labels with uniform signal words, pictograms and hazard statements must be applied to the container. A Safety Data Sheet (SDS, formerly MSDS) must be obtained from the chemical manufacturer and kept in a specific format that contains 16 predefined sections.
In addition to the proper labels, employers also must train employees to know and understand the meaning of those labels and SDS sheets. The last but most important step in the process is to make sure to wear the proper PPE based on exposure levels.
According to Moore, one issue with OSHA’s hazard communication rules that came up often during the COVID-19 pandemic were companies’ use of secondary containers for consumer-based products, primarily for cleaning and disinfecting.
“OSHA has a consumer exception to the hazard communication rule that applies to consumer products, but that only applies to consumer products that are used in the same amount and as the same frequency that consumers would typically use them,” he said. “OSHA will almost always take the position that, in a business environment, those products are used at a greater frequency and in greater quantities than a consumer would use them and will therefore require compliance to hazard communication rules. It is always best to have those containers properly labeled and to have SDS sheets for them.”
A culture of safety
Moore and Brewster agree that when it comes to developing a robust culture of safety at a workplace, the most important aspect is to have buy-in and collaboration from top to bottom.
It starts by making safety a core value of the company.
“Sometimes there will be production obligations that run in tension with safety,” Moore said, “but you can’t compromise safety. That has to be the message from the top down.”
It also requires having employees fully bought into the same philosophy, not just through training but also by supporting workplace behaviors that enhance and improve safety.
“We have a safety committee that meets once a month and is comprised of employees, it’s an open floor where we focus on safety issues and come up with solutions to deal with those issues,” Brewster said. “Giving employees a voice in their own safety is important. When everyone feels responsible for each other’s safety, that helps create a culture and a buy-in that helps prevent accidents.”
Atlantic TNG also has unlabeled, anonymous boxes throughout the plant in case an employee has a safety concern but is hesitant to voice it to a supervisor or fellow employees.
The goal is for every employee to understand that these safety issues can affect them and their coworkers. All employees deserve to go home in the same condition in which they came. Empowering employees to look out for one another and report issues to their managers is less about getting each other in trouble and all about making sure everyone can go home to their family at the end of the day.
And that’s the most important part of any job, to care for our loved ones.
Hugh Martin, P.E., is the director of technical resources at NPCA.