Frequent Health & Safety Compliance Challenges

by | Jul 7, 2020 | Environmental, Safety, Transportation, Uncategorized

EnSafe Webinar | June 3, 2020 | Frequent Health & Safety Compliance Challenges

 This Webinar was presented by Leo Old, PE, CIH, CSP, EnSafe’s Vice President of Health and Safety Services, and included a slide presentation with examples of common hazards or challenges faced by facilities in an effort to promote a culture of safety in the workplace. It also referenced historical safety failures at facilities and how maintaining proper safety procedures and practices could have saved lives.

 The information focused on twelve Compliance Elements that EHS professionals see most often and the regulations cited are from either Occupational Safety and Health Administration (OSHA) or National Fire Prevention Association (NFPA) sources. Quite often, the NFPA Life Safety Code is stricter than the OSHA regulations.

Topics covered included:

    • Walking-Working Surfaces (29CFR 1910.21 – 1910.30)
        • This includes keeping surfaces clean and orderly, raised surfaces above 4’ high having adequate guard rails or coverings to prevent falls, proper training for the work area, and vertical clearance of stairs is at least 80”. These measures are examples of the simple, but sometimes overlooked, steps that can make all the difference in preventing injury in the workplace.
      • Exit Routes / Life Safety (29 CFR 1910.33 – 1910.39)
        • Too many historical examples have ended in tragedy when these requirements were not met. Having proper exit routes to allow all workers to exit the site in the event of an emergency is of the utmost importance. Making sure exit paths are not blocked or crowded by things being “stored” in the exit path is the most common problem.
      • Flammable Liquids (29 CFR 1910.106, 40 CFR 262.16, NFPA 30, NFPA 77, NFPA 91)
        • Keeping the liquids in a place to prevent them from igniting from static discharges, spark generating equipment, and other sources of ignition is vital. Storage cabinets must be maintained in an operable condition. Process equipment should be bonded and grounded and exhaust systems tested annually to evaluate performance.
      • Personal Protective Equipment (29 CFR 1910.132 – 1910.140)
        • Maintaining Personal Protective equipment is just as important when you are wearing it as when you are not. Improper storage can lead to filters not working correctly on respirators or seals wearing out, gloves and other equipment being damaged from heat or moisture if left in the sun, or not completely dried after cleaning. Always make sure you are taking care of equipment so it can take care of you.
      • Respiratory Protection (29 CFR 1910.134)
        • Where respirators are required, there must be a written respirator program, annual training must be provided to employees required to use respirators, and the program evaluated periodically to determine effectiveness.
      • Lockout Tagout (29CFR 1910.147)
        • Don’t forget about them! When you don’t use something regularly, it’s easy to forget about it. When lockout tagout is required, make sure your tag is in good condition and legible because, if you neglect your tag, you might forget what’s on it. Make sure you are taking care of it by making sure you can still read it once a month.
      • Fire Protection (29 CFR 1910.155 – 1910.165, 1910.251 – 1910.255, NFPA 25, NFPA 51B, NFPA 72)
        • Have the right tool for the right job. Make sure the fire extinguishers are the right option to deal with a fire should you have one. This includes the size and type of extinguishers. Are the extinguishers spaced correctly? Will the amount of fire suppressant be enough for the area it’s supposed to cover? Will the chemicals react in an undesired way with what is stored in that area? Is a fire blanket a better option in some locations? All of these questions are examples of things you should ask when looking at fire protection for your facility.
      • Powered Industrial Trucks (29 CFR 1910.178, NFPA 505)
        • You know what you are doing with it, do your co-workers? Make sure those around you know what you are doing so they can also make space and avoid standing or placing things in areas that could be hazardous. Also, make sure that you are using a Powered Industrial Truck in the way it was intended. Many accidents start with “It’ll be fine.” Don’t take shortcuts and, if you are unsure if a PIT should be operating in an area, find out beforehand and make sure it is only used in approved areas. A couple minutes spent getting the answer could prevent an accident or even save a life.
      • Machine Guarding (29 CFR 1910.211 – 1910.219)
        • No shortcuts. Don’t remove guards. Make sure they fit and are covering all areas of the machine that might present a safety risk. Make sure they protect the operator and all other employees from moving parts and other potential hazards caused by its operation.
      • Electrical (29 CFR 1910.301 – 1910.308, NFPA 70)
        • Make sure wires are covered and only work on them if you are trained and qualified. Make sure everyone at the facility knows if electrical work is going on to avoid accidents. Make sure temporary lighting and other applications are indeed temporary and proper installation takes place as soon as possible.
      • Industrial Hygiene – Air Contaminants / Noise (29 CFR 1910.95 – 1910.1000 – 1910.1053)
        • Make sure employees are not exposed to sustained noise or reduced air quality without adequate protection and monitoring to ensure the safety and well being of those working in those conditions.
      • Hazard Communication
        • Communication is everything. Make sure you are taking time to speak, listen, and receive feedback. This will ensure that the message you are sending when you communicate is being received and understood by others. Never assume someone understands when communicating about safety; make sure they communicate back that they have understood the message.

Why do EHS professionals see issues and problems in these areas so often when they perform assessments? Lack of training is usually the underlying cause.