Posts Tagged ‘PPE’

Are You Providing Adequate Training?

Thursday, September 15th, 2011

Failure to adequately train employees concerning job safety is a serious omission that can get an employer into a lot of trouble. Following is a lawsuit that makes the point.

A worker, who was not wearing work gloves when he was injured, sued his employer, claiming that the employer did not instruct him that wearing leather gloves was a mandatory safety precaution. This same employee passed a written test before he could work on railroad tracks for the company. He was taught how to set railroad track spikes during the on-the-job training.

At the pre-shift meeting that day, his assignment was discussed. He would be using a 10-pound steel maul head to manually set .8-pound steel spikes into railroad ties. An independent contractor was delegated as foreman in charge of the jobsite, but the employee’s supervisor, from the worker’s company, was ultimately responsible for safety.

The Accident
A steel spike shot out of the tie, striking and cutting the back of the employee’s wrist. No one was there to witness the accident. The employee’s supervisor was in a worksite trailer about 5 miles away. Even though the company had provided PPE to all employees, including leather work gloves, the employee was not wearing them when he was injured. The injury resulted in major surgery to repair tendons and nerves.

The company conducted an accident investigation and concluded that the injury was solely the employee’s fault because he had not followed the company’s safety rules and procedures, which contained expressed and repeated instruction that employees were responsible for complying with all safety rules and instructions, including wearing assigned PPE and following specific rules for using spike maul and setting and driving spikes.

The employee charged that the company was at fault because it did not make him aware that wearing the gloves was mandatory. And while he noted that 6 months earlier, his supervisor initiated a practice of training new employees by having them watch a series of safety videos, he had been working for the company for over 2 years, and therefore did not view these same videos until after his accident.

Keep in mind that the employee did admit to receiving a copy of the company’s safety rules and procedures, he argued that the rules did not address setting spikes or the use of gloves and the company did not have written rules regarding the use of gloves.

Eventually the employee filed suit against the company, alleging it had violated the Federal Employers’ Liability Act (law applicable to railroads). He sought compensatory damages for his injuries, past and present medical care, past and future mental and emotional distress, and post and future lost earnings.

So how do you think the court ruled?
The railroad company requested the court to dismiss the claims, which was denied saying that a jury should decide the matter and that there was sufficient evidence from which the jury could reasonably conclude that the employer was negligent for failing to define and enforce its own safety rules and for failing to properly train employees.

What Can You Do To Prevent Negligence Claims

First, make sure all employees are adequately trained. This includes all new hires and more importantly, existing employees who may be doing a job for the first time. Just because you have an employee working for you for years doesn’t negate the fact that they may not have performed a certain task and as such must be properly trained on the requirements of the task.

Second, provide PPE and require its use. It’s the responsibility of the employer to instruct employees about when and how to use PPE. Make sure they know they must wear it. And make sure you monitor that they are actually using the required PPE. This means that the site supervisor or foreman needs to be available to check in on the job and the employees.

Third, institute a company-wide Disciplinary Program and enforce it. The program should define the company’s policy of enforcing safety practices and the penalties that will be in place if an employee chooses to disregard them.

Finally, continuous learning through on-going safety training enforces a culture of safety and fosters good behaviors. Safety Training Resources in St. Charles, Missouri  is committed to helping companies institute a strong safety culture and can help bring all levels within an organization to work on a  common goal – Worker Safety and Health. Call us today to schedule an on-site safety consultation. Have you included safety training in your budget for 2012?


Safety Training Resources Steps Towards Effective HazCom

Thursday, May 19th, 2011

Safety Training Resources takes 7 simple steps to ensure an effective hazard communication program.

1. Train supervisors and safety personnel to communicate hazard information and safety procedures effectively. Also train them in general communication skills so that they can interact more successfully with employees.

2. Encourage employee participation in the development and implementation of workplace safety and health programs—for example, through safety committees and other team initiatives.

3. Welcome employee suggestions about ways to improve chemical safety in the workplace. Take their concerns and suggestions seriously and incorporate them into safety programs. Remember that to be truly effective, hazard communication must involve two-way communication.

4. Emphasize safety protections as well as hazards in hazard communication and other chemical safety training programs. Make sure employees understand that working with chemicals is safe as long as they follow established work practices, use appropriate engineering controls, and wear assigned PPE.

5. Provide intensive MSDS and label training. Teach employees how to find and interpret the information in the MSDS and on the label. Provide them with glossaries defining technical terms in plain language. Make sure that they are comfortable with their ability to understand and use chemical safety and health information. Your training effort is not complete until they are.

6. Involve experienced, knowledgeable employees in training programs as trainers and coaches. These workers have a natural rapport with trainees, and they are also well positioned to provide practical information about how to perform the job safely and efficiently.

7. Work hard to build trust between management and employees by demonstrating your commitment to employee safety and health every day. Involve top management in safety awareness campaigns and feature safety as a fundamental organizational goal.


Safety Training Resources Illuminates OSHA’s Expectations: The Electrical Safety Questions OSHA Will Ask During an Investigation

Friday, May 13th, 2011

When it comes to electrical safety, OSHA standards can be technical and confusing. What requirements do safety managers need to know?

Wouldn’t it be nice to know exactly what OSHA is training its inspectors to look for during an inspection that includes electrical safety, including surprising new areas of emphasis based on national OSHA directives?

Safety Training Resources covers some of the typical electrical safety questions that OSHA inspectors will ask during a field investigation, what they mean and how to be prepared and in compliance.

A good starting point is to understand OSHA’s approach to electrical safety. OSHA’s goal is for employers to identify all electrical hazards, both potential and actual. In the past, OSHA focused on process changes, encouraging companies to de-energize circuits before working on them, perform lockout/tagout procedures and develop ongoing safety programs that include worker training and retraining. A more recent area of emphasis is arc flash safety, which means electrical safety professionals must analyze the workplace for shock and arc flash hazards, establish safe protection boundaries and define what personal protective equipment (PPE) must be used within these boundaries.

For electrical safety in the workplace, OSHA relies on expert consensus bodies such as the National Fire Protection Association (NFPA) and its standards published in NFPA 70E. To ensure that employers are following NFPA and OSHA guidelines, OSHA trains its inspectors and compliance officers to ask specific questions in the event of an electrical safety incident. Some typical questions follow.

1.  Is there a description of the circuit or equipment at the job location?

OSHA expects employers to know their workplaces. If an employer cannot provide a written description or drawing of the circuit or equipment, then the compliance officer may assume that the employer has not assessed the facility for electrical hazards.

2.  Is there a detailed job description of planned work?

In order to know which safety procedures to use, the worker must be provided with a description of the job task. OSHA publication 29 CFR 1910 lays out employer responsibilities for protecting their workers from electrical safety hazards. It states that the employer shall train workers to use safe work practices that are designed to avoid injury.

3.  Can you justify why equipment cannot be de-energized or the job deferred until the next scheduled outage?

Per OSHA 1910.333(a)(1), live parts to which an employee may be exposed must be de-energized before the employee works on or near them, unless the employer can demonstrate that de-energizing introduces additional or increased hazards or is not feasible due to equipment design or operational limitations. (Live parts that operate at less than 50 volts to ground need not be de-energized if there will be no increased exposure to electrical burns or to explosion due to electric arcs.)

The message is clear: never work on live circuits unless it is absolutely necessary. OSHA allows work on live circuits in some cases, but the reason cannot be simply that turning off the power is inconvenient or will interrupt production. Nor can workers use the excuse that they didn’t have the authority to shut off power.
When it is necessary to perform work on energized equipment, OSHA 1910.333(a)(2) requires safety-related work practices to be used and NFPA 70E Article 110.8(B)(1) requires an Electrical Hazard Analysis before work is performed on live equipment operating at 50 volts and higher.

Other questions you can expect from an OSHA inspector include:

  • What about safe work procedures?
  • Has a detailed work procedure been established?
  • Are there detailed descriptions of work practices to be employed?
  • Was a job briefing checklist performed, and was the job briefing completed for those performing the work?
  • Was proper management approval secured?

OSHA wants employers to make electrical safety procedures and practices part of regular work processes. Several annexes to NFPA 70E offer guidelines for lockout/tagout procedures, checklists and approvals. NFPA 70E annexes are not strictly “enforced” by OSHA, as they are appendices to the NFPA standard. However, OSHA inspectors and investigators will ask if the content and information contained in these annexes was followed and adhered to.

Safety Training Resources will help you prepare to answer these questions when an OSHA inspector comes knocking on your door:

  • Were required electrical safety analyses performed?
  • Was an arc flash hazard analysis performed?
  • Were flash protection boundaries established?
  • Were all other potential electrical hazards identified?

OSHA regulations state that every employer shall furnish a place of employment free from recognized hazards that are causing or likely to cause death or serious physical harm, and that the employer must assess the workplace to determine if hazards are present and select PPE to protect employees. When it comes to electrical safety, OSHA refers to NFPA 70E, which requires employers to conduct an electrical hazard assessment consisting of a shock hazard analysis and an arc flash hazard analysis before work is performed on live equipment operating at 50 volts and higher.

These requirements may be fairly complex, as they involve calculating the potential fault current at each piece of equipment, understanding the characteristics of the overcurrent protective devices and how they are coordinated for each circuit and creating or updating one-line electrical drawings. Complex or not, OSHA inspectors are trained to ask if these analyses were performed, because they are essential to reducing the number of arc flash-related deaths and injuries that occur each year, as well as ensuring a safe installation.

When the safety of any job task involves electricity or electrical equipment, ask yourself these questions:

  • Were proper tools and equipment used?
  • Was the necessary PPE determined?
  • Were the proper insulated tools used?
  • Were insulated blankets and/or sheeting used to properly cover all of the live parts?

OSHA 1910.132 requires employers to assess hazards, select PPE and make sure that employees are trained how to use it. Electrical PPE, safe work practices such as lockout/tagout and safety training are covered by OSHA 29 CFR 1910.301-.399, also known as Electrical Subpart S.

For example, OSHA 1910.333 (a)(1)(i) states: “Employees working in areas where there are potential electrical hazards shall be provided with and shall use, electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed.”

For electrical workers, this standard’s effect is multi-fold. First, employers must facilitate workers’ understanding of the PPE required for each task on each piece of equipment. This may be communicated via a work order, a descriptive label on the equipment or a one-line drawing. Second, employers must select the PPE, which includes insulated tools and protective clothing. Third, the employer is required to train workers in safe work practices – and in particular, how to match the PPE to the level of the electrical hazard. And finally, OSHA 1910.269(a)(2)(iii) requires employers to “determine, through regular supervision and through inspections conducted on at least an annual basis, that each employee is complying with the safety-related work practices …”

4.  Were the workers performing the tasks qualified to do so?

OSHA defines qualified workers as those specially trained to work on live electrical equipment. Qualified workers must protect themselves against all electrical hazards including shock, arc flash, burns and explosions. Training is key. Even an experienced electrician is not “qualified” in OSHA’s eyes unless the employer can show proof of the appropriate training and certifications.

OSHA 1910.332(b)(2) also requires unqualified workers to be trained in the electrical safe work practices that are necessary for their safety. Unqualified workers, such as painters or cleaners, occasionally come into contact with energized equipment, and therefore they must be trained to recognize and avoid electrical hazards.


Safety Training Resources Shares Tips for Managing Safety in Machine Operation Areas

Tuesday, May 10th, 2011

Machine operation areas differ from workplace to workplace. Production areas in manufacturing plants expose workers to a wide variety of potential hazards. During an OSHA inspection, violations can range from machine guarding to electrical hazards. Safety in machine operation areas is an ever-changing challenge that requires continuous management.

Design for Safety

Machine operation areas should be designed for safety. For example:

  • Machines should be equipped with all the necessary safeguards.
  • The area should be well lit so workers can see what they’re doing and where they’re going.
  • There should be adequate space between machines and materials and finished products.
  • Walkways should be clearly marked with yellow lines to separate them from machine work areas.
  • Floors should be made of, or coated with, a nonslip material.
  • There should be a good general ventilation system and a local exhaust system for any processes that produce dusts, mists, fumes, or vapors.

Insist on a Clean Work Area

A well-maintained, orderly production area is another essential. Look around the machine operation areas in your facility. What do you see?

  • Are floors wet, dirty, or cluttered with tripping hazards?
  • Are tools, materials, and other items left lying around when they ought to be put away after use?
  • Is there trash and debris everywhere?
  • Are carts or pallet jacks with materials or finished products blocking walkways?

 If you don’t see reasonably neat, clean work areas, you might be looking at an accident waiting to happen.

Maintain Proper Storage

Along with good housekeeping comes proper storage of raw materials and finished products.

Make sure employees do:

  • Stack materials to be processed on a secure base.
  • Place heavy objects on the bottom of the stack.
  • Use ladders to reach stored items overhead.
  • Wear gloves when handling materials to avoid cuts and scrapes.
  • Secure stored items so that they can’t topple over on someone’s head or fall to the ground and get damaged.

 Make sure employees don’t:

  • Store items too close to machinery.
  • Stack items so high that they could topple over or block fire sprinkler heads.
  • Pile materials too close to sources of heat or electricity.
  • Store items so that they block or stick out into walkways.
  • Lift incorrectly or try to lift and carry objects that are too heavy to handle alone.

Emphasize Safeguards and Lockout

Machine guarding violations generally hit OSHA’s Top 10 list every year. To avoid citations and keep workers safe, make sure machine operators understand the reason for, and operation of, machine guards and safety devices. No machine should ever be operated without properly functioning safeguards.

An effective lockout/tagout program is another essential safety component for machine operation areas. Employees authorized to repair and maintain machinery should be specially trained and certified in lockout/tagout procedures.

But you can’t stop there. All employees who work in machine operation areas should receive lockout/tagout training to be sure they understand the procedure, OSHA requirements, and your rules—even if they don’t actually perform lockout/tagout.

Fires and Medical Emergencies

Fires are an ever-present danger in machine operation areas. Avoid fires by considering all potential fire hazards and the precautions necessary to prevent ignition.

Also, just in case you fail to anticipate every possible risk, make sure to have fire extinguishers on hand that can contain the classes of fires common to machine operation areas. For example:

Class A—Combustibles (paper, cardboard, wood)
Class B—Flammable liquids (solvents, oil, etc.)
Class C—Electrical fires

Multipurpose extinguishers may also be an appropriate choice for machine operation areas.

OSHA has strict requirements for the use and placement of portable fire extinguishers (see 29 CFR 1910.157).

First aid kits should also be available, and employees should know how to report accidents and medical emergencies.

The machines in your workplace are hard workers. But they’re only machines. They can only do the grunt work. They can’t think. It’s your human workers who have to do the thinking in order to prevent machine accidents.

To be sure your workers are thinking straight and fully in command when they operate machinery, they must be properly trained.

Training for machine operators should include at a minimum:

  • Machine hazards
  • Machine operation, including safeguards and emergency stops
  • Lockout/tagout procedures and rules
  • PPE
  • Machine area housekeeping and storage rules
  • Slips, trips, and falls
  • Maintenance schedules and authorizations
  • Procedures for reporting malfunctions and handling repairs
  • Emergency response, including fires and first aid

 PPE

PPE for machine operators usually includes:

  • Eye and face protection (safety glasses with side shields or goggles as well as a face shield when there’s a risk of flying particles)
  • Hearing protection when noise levels exceed regulatory limits
  • Head protection if there is a risk of materials or other objects falling from above
  • Foot protection to keep feet and toes safe from falling materials or machine movement

 Gloves should be worn to protect hands when handling materials, but machine operators must understand that gloves should not generally be worn when operating machinery. Gloves can interfere with precise grip or get caught at pinch points or at the point of operation, which can cause crushed fingers or amputations.