SUMMIT COUNTY SAFETY COUNCIL: FOCUS ON MACHINE GUARDING, LOCKOUT TAGOUT, & OSHA TRENDS

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1 SUMMIT COUNTY SAFETY COUNCIL: FOCUS ON MACHINE GUARDING, LOCKOUT TAGOUT, & OSHA TRENDS Presented by Rob Medlock, Senior VP of General Industry at SCT

2 2 What s Happening with OSHA? A look at OSHA headlines in 2018

3 A new leader? 3 Meet Scott Mugno à Background: VP of safety, sustainability and vehicle maintenance at FedEx Ground Feb Dec. 2011, was managing director of corporate safety, health and fire prevention until his promotion to VP Status? Nominated to lead OSHA by President Trump in Approved by the Senate Health, Education, Labor and Pensions (HELP) Committee, but his status expired at the end of 2017 because his nomination never went to the Senate floor for a full vote. Appeared before the HELP Committee again in January 2018 and was re-approved and sent back to the Senate for a full floor vote.

4 Fewer inspectors? Budget cuts? 4 According to January 2018 reporting from NBC News, a Freedom of Information Act (FOIA) request revealed: OSHA lost 40 inspectors through attrition after the new administration took office, and as of October 2, 2017, no new hires had been made to fill the vacancies Those 40 inspectors made up 4% of OSHA s total federal inspection force, which fell below 1,000 inspectors by early October 2017 When the new administration took office it implemented a government-wide hiring freeze and pushed workforce reduction through attrition; and proposed budget cuts across the board A Labor Department spokesperson stated that the agency had hired several additional inspectors since early October, but declined to specify the number of inspectors hired

5 OSHA 300 Logs? Electronic recordkeeping? 5 The OSHA 300A Form summarizes job-related injuries and illnesses during the previous year. OSHA requires this summary form to be displayed between February 1 and April 30 so if you haven t posted it yet, you re late! OSHA recordkeeping and reporting made headlines in 2016 and 2017 with the launch of the agency s online reporting platform, called the Injury Tracking Application (ITA). The electronic service was intended to improve workplace safety while giving researchers a pathway to more easily examine and identify new workplace hazards. Companies required to comply with the electronic posting standard include businesses with 250 or more employees, or those with employees in certain high-risk areas. Since electronic recordkeeping was introduced, there has been much debate over whether or not the electronic posting is necessary and fully secure. Certain states have OSHA-approved State Plans that have not, as of yet, adopted the requirement to submit electronic OSHA injury and illness reports. Businesses in these states California, Maryland, Minnesota, South Carolina, Utah, Washington, and Wyoming are not currently required to submit electronic data to OSHA through the ITA.

6 Take it away, Rob! 6 And now, time for the Top 10!

7 7 Top 10 OSHA General Industry Violations 29 CFR 1910 for Fiscal Year 2017 (Oct Sept. 2017) 1. Hazard Communication, CFR Citations: 3, The Control of Hazardous Energy (Lockout/Tagout), CFR Citations: 2, Respiratory Protection, CFR Citations: 2, Powered Industrial Trucks, CFR Citations: 2, General Requirements for all Machines, CFR Citations: 1, Wiring Methods, Components, and Equipment for General Use, CFR Citations: 1, General Requirements, CFR Citations: 1, General Requirements, CFR Citations: Occupational Noise Exposure, CFR Citations: Maintenance, Safeguards, and Operational Features for Exit Routes, CFR Citations: 379

8 8 Focus on #5 & #2 Machine Guarding & Lockout/Tagout (LOTO)

9 #5 General Requirements for All Machines 9 Coverage Area of Standard: Statistics from FY 2017 Found in Subpart O Related specifically to Machine Guarding. One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards. Citations: 1,954 Inspections: 1,752 Penalties Assessed: $11,355,933

10 10 How to Approach Machine Guarding

11 11 OVER. UNDER. AROUND. THROUGH

12 Machine Guarding Guide: Assessment 12 Conduct an audit of any facility with machinery Identify the following: Where incidents of injuries or illnesses have occurred Where near misses have occurred The types of machines in the facility The number of machines in the facility Are the machines in the facility referenced within OSHA s Machine Guarding etool?

13 Machine Guarding Guide: Standards 13 OSHA standards regarding Machine Guarding are the gold standard, but what other standards are applicable to your facility? Become familiar with consensus standards and other resources for safety and health as they relate to machine guarding These can include: ANSI Standards NIOSH FACE Reports ASME Standards

14 Machine Guarding Guide: Protective Systems 14 Proper design of protective systems is instrumental in providing sufficient coverage for your employees operating or maintaining any machinery. Protective systems can include: Physical barriers Engineering controls/devices Proximity exposure procedures Personal Protective Equipment (*NOTE: PPE should always be the last form of defense. Engineering and administrative controls should be used to try and abate or eliminate a hazard before PPE is implemented.*) Additionally, a written safety program is required by OSHA standards

15 Machine Guarding Guide: Training & Assistance 15 As Machine Guarding is a top area of concern for OSHA, regular evaluation of related safety programs is recommended Consistent in-house assistance from trained employees and management is crucial for a successful program Consider seeking support from a third-party safety provider. An annual audit or review can ensure your policies and programs are on track and accommodate for any updates in federal standards.

16 16 How to Approach Lockout/Tagout LOTO is responsible for the most fatalities and significant OSHA cases.

17 #2 The Control of Hazardous Energy (Lockout/Tagout) 17 Coverage Area of Standard: Statistics from FY 2017 Found in Subpart J Covers servicing and maintenance of machines/equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could cause injury to employees. Establishes minimum performance requirements for the control of such hazardous energy. Citations: 2,884 Inspections: 1,659 Penalties Assessed: $14,957,674

18 LOTO Guide: Steps to Safety Identify Energy Sources 2. Specific Procedures 3. Employee Interaction with Machines (How are workers exposed? Servicing activities?) 4. Training Authorized vs. Affected 5. Minor Servicing Activities 1. Inherent to Production Activities 2. Routine or Repetitive Activities 3. Alternative Effective Protective Measures

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23 Top 10 OSHA Dos & Don ts 23 Dos 1. Do have a plan 2. Do have OSHA savvy representation 3. Do have OSHA written programs organized & accessible 4. Do determine purpose, scope & authorization for inspection Don ts 1. Don t wing it 2. Don t have representation unfamiliar with OSHA 3. Don t provide programs that have not been implemented or were shelved. 4. Don t just let OSHA have free reign

24 Top 10 OSHA Dos & Don ts 24 Dos 5. Do duplicate photos; take notes of activity & conversations 6. Do challenge expansion of inspection 7. Do answer questions accurately & stick to subjects briefly Don ts 5. Don t trust your memory. Time changes stories & distorts facts 6. Don t Let them go beyond scope of initial inquiry 7. Don t talk too much or B.S. the officer. Cooperate, but don t be a doormat

25 Top 10 OSHA Dos & Don ts 25 Dos 8. Do have consultative audits from a recognized source 9. Do have management representation during interviews 10. Do cooperate with OSHA to a limit Don ts 8. Don t think in-house audits are good enough 9. Don t pressure employees after OSHA interviews; debriefing is OK 10. Don t require a warrant unless scope is unreasonable

26 Employee Misconduct Defense 26 More important than ever to establish strong unavoidable employee misconduct defense. All four elements required (1) Program for the specific hazard, e.g. fall, electrical, lead, asbestos, cadmium, forklift (2) Employee training (documentation) (3) Prior enforcement (disciplinary records) (4) No reasonable opportunity for supervisor to identify and correct hazard If you do not train, you cannot make the unavoidable employee misconduct defense

27 27 Questions? When in doubt, call/ Rob at: