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

Similar documents
ACC Environmental Legal Quick Hit Webinar

Introduction to OSHA. 2-hour Lesson. Directorate of Training and Education OSHA Training Institute

OSHA Primer ABA OSH Law Committee Midwinter Meeting

Outreach Training Program

Recent OSHA Changes and What Employers Need to Know

National Safety Education Center. Course Catalog General Industry. Maritime Industry. Construction Industry

We Can Help OSHA Update. Peter Grakauskas

Outreach Training Program

When MIOSHA Enforcement Visits

OSHA (PESH) Records. Presented by: Doug Miller. Occupational Safety Consultants, Inc.

Course Syllabus. ENVH 460/560 Occupational Safety Management. ENVH Credits ENVH Credits. Instructor: Rick Gleason, MSPH, CIH, CSP

Wisconsin Public Sector Employee Safety Program

Spring Quarter, 2014, 4 credits for ENVH 560 / 3 Credits for ENVH 460, 11 weeks

Safety Best Practices Manual

8 Fun Steps to OSHA s Respiratory Protection Standard

Accident Prevention Process

The policy and procedures described in this program apply to all MCC employees.

OSHA Compliance Update for Long Term Care

# Personal Protective Equipment

OSHA 10-Hour AND OSHA 30-Hour

Safety and Health Movement: An Overview p. 1 Developments Before the Industrial Revolution p. 2 Milestones in the Safety Movement p.

REVISION: This revised Management Directive (MD) updates TSA MD , dated January 29, 2004.

HOW TO SURVIVE AN OSHA INSPECTION

2018 TRAINING SCHEDULE

OSHA Update. Miriam Koesterich, MS, CSP, CIH Occupational Safety and Health Administration

Get your OSHA and EHS training from an authorized OSHA Education Center OSHA & EHS Courses

(Nov. 16, 2013), v6

What is the difference between the OSHA 10hr and 30hr?

Occupational Safety & Health Training Catalog

A. Occupational Safety and Health Act of 1970 (OSH Act of 1970), Section 19, Federal Agency Safety Programs and Responsibilities.

AWARD APPLICATION. Send Via Mail. Send Via

OSHA Update. OhSh*tHereAgain. PRESENTED BY: Dale Varney Compliance Assistance Specialist Springfield Area Office

Introduction to OSHA

January-June 2015 COURSE CATALOG

OSHA: 45 years of Progress on Safety and Health

Template F-circle lt grey 1

U.S. CONCRETE, INC. SAFETY POLICY and PROCEDURE MANUAL

Self Assessment Guide for an Effective Safety and Health Program

120 White Bridge Rd. Nashville, TN Control of Hazardous Energy Program OSHA (lockout/ Tagout) standard 29 CFR

INJURY AND ILLNESS PREVENTION PROGRAM

OSHA Regulations- Credit: CNBT Required. Title of course. ies

Creating An Effective OSHA Compliance Program

Certified Healthcare Safety Environmental Services (CHS-EVS) Examination Blueprint/Outline

Certified Healthcare Safety Long Term Care (CHS-LTC) Examination Blueprint/Outline

INJURY AND ILLNESS PREVENTION PROGRAM

New Hire Safety Orientation Safety Through Involvement

PROCEDURE 806 HEALTH AND SAFETY

Emerging Safety Resources for Brewers

Overview Of Cal/OSHA s Injury & Illness Prevention Program Standard

Rocky Mountain Education Center

Midwest OSHA Education Centers

PRESENTED BY APRIL 18, The University of Texas MD Anderson Cancer Center Houston, Texas

OSHA's Revised Recordkeeping Rule 1

Injury and Illness Prevention Program and Safety Procedures Manual

STATE OF NORTH CAROLINA OFFICE OF STATE PERSONNEL 1331 Mail Service Center Raleigh, North Carolina August 16, 2012

Outreach Training Program

Policy #2 INJURY & ILLNESS PREVENTION PROGRAM Version 2.2

Objectives. You Never Give me Your Money. Eligible Programs. Who is Eligible to receive a Grant? NYS Grants and How to Get Them.

Training Course Descriptions

OSHA 29CFR 1960 Basic Program Elements for Federal Employee Occupational Safety and Health Programs and Related Matters

Injury and Illness Prevention Program BrightStar Care of San Francisco & Marin

Who Is OSHA? Who Is PERRP?

HEALTH AND SAFETY COMMITTEES Getting Started

Chapter 15. Occupational Safety and Health. Statutory Basis 1/12/2009. Employment Law for Business, 6 th ed. Bennett-Alexander

CHEMICAL HYGIENE PLAN

An OSHA Inspection in the Laboratory

CHAPTER 2 RESPONSIBILITIES

T RAINING C ATALOG. Register Today! Call or visit uta.edu/ded/osha. Your #1 Source for OSHA Training and Professional Certifications.

Facilities Department Accident Prevention Plan

CCIA SAFETY RECOGNITION AWARDS

Voluntary Protection (VPP) Orientation

Occupational Safety and Health Administration Directorate of Science,Technology and Medicine

Director, National Institute for Occupational Safety and Health. FROM: Iowa FACE Program Case No. 2004IA005 Report Date: 5 June 2008

Guide To Compliance Training. for Michigan School Employees

Chrysoula J. Komis, PhD, MS, CIH, CSP, CHMM, CPEA, FAIHA Senior Scientist and Senior Project Manager

Kelly Bubolz Compliance Assistance Specialist Appleton OSHA Office January 15, 2013

New OSHA Recordkeeping Course to be Offered at Richland

Palm Beach State College. Florida s First Public Community College SAFETY MANUAL

Presented by: Nickole Winnett, Esq. Jackson Lewis P.C. (703) September 17, 2015

Tamkene Saudi Training Center Leading Health & Safety Innovation in the Middle East

Citation and Notification of Penalty. Company Name: U.S. POSTAL SERVICE Inspection Site: 835 S 7th Street, Louisville, KY

Personal Protective Equipment Program. Risk Management Services

MTI LEVEL ONE BOOT CAMP

LAKESIDE FIRE PROTECTION DISTRICT

Environmental Health & Safety Course Information

APPENDIX A MINIMUM BASIC OUTLINE FOR ACCIDENT PREVENTION PLANS

COMPLIANCE MADE EASY

OSHA Healthcare Inspections

MINNESOTA SAFETY COUNCIL CONTINUING EDUCATION COURSE CATALOG January - June 2012

COMPLIANCE WITH THIS PUBLICATION IS MANDATORY

Contact Hours FL (CE version ONLY) Suggested Target Audience. staff that provide care to patients. Page 1 of 8 Updated: 10/30/2017

Yosemite Community College District Biennial Inspection

CONNECTICUT CONSTRUCTION INDUSTRIES ASSOCIATION, INC.

CONNECTICUT CONSTRUCTION INDUSTRIES ASSOCIATION, INC.

United States Senate. Committee on. Health, Education, Labor & Pensions

Training Needs Assessment Tool

NAVY RECRUITING DISTRICT NEW ORLEANS INSTRUCTION B. From: Commanding Officer, Navy Recruiting District New Orleans

Training Needs Assessment for EHS-Related Topics (Revised 11/17)

Safe at Work Ontario. Ronald Landry (A) Provincial Coordinator, Industrial Health & Safety Program Operations Division

Guide for the Incident Investigation Form (Incident Investigation Report)

Transcription:

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

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

A new leader? 3 Meet Scott Mugno à Background: VP of safety, sustainability and vehicle maintenance at FedEx Ground Feb. 2000 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 2017. 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.

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

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 20-249 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.

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

7 Top 10 OSHA General Industry Violations 29 CFR 1910 for Fiscal Year 2017 (Oct. 2016 Sept. 2017) 1. Hazard Communication, CFR 1910.1200 Citations: 3,624 2. The Control of Hazardous Energy (Lockout/Tagout), CFR 1910.147 Citations: 2,884 3. Respiratory Protection, CFR 1910.134 Citations: 2,600 4. Powered Industrial Trucks, CFR 1910.178 Citations: 2,065 5. General Requirements for all Machines, CFR 1910.212 Citations: 1,954 6. Wiring Methods, Components, and Equipment for General Use, CFR 1910.305 Citations: 1,449 7. General Requirements, CFR 1910.303 Citations: 1,360 8. General Requirements, CFR 1910.132 Citations: 906 9. Occupational Noise Exposure, CFR 1910.095 Citations: 520 10. Maintenance, Safeguards, and Operational Features for Exit Routes, CFR 1910.037 Citations: 379

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

#5 General Requirements for All Machines 9 Coverage Area of Standard: 1910.212 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 How to Approach Machine Guarding

11 OVER. UNDER. AROUND. THROUGH

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? https://www.osha.gov/sltc/etools/machineguarding/index.html

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

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

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

#2 The Control of Hazardous Energy (Lockout/Tagout) 17 Coverage Area of Standard: 1910.147 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

LOTO Guide: Steps to Safety 18 1. 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

19

20

21

22

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

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

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

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 Questions? When in doubt, call/email Rob at: 440-449-6000 RMedlock@sct.us.com www.sct.us.com