How Maintenance Teams can Avoid the Top OSHA Violations

Everything maintenance teams need to know about OSHA, its regulations, compliance standards and how to avoid OSHA violations.

Here’s a scary stat: 85 health and safety violations were committed every day across the US in 2018. In total, there were more than 31,000 fines doled out for breaking the Occupational Safety and Health Administration’s (OSHA) top 10 health and safety violations alone.

Besides the potential for accidents, injury, and death, these fines inflicted a heavy toll on the bottom line, costing businesses over $400 million last year.

Many of the top OSHA violations have a connection to everyday maintenance tasks, especially for those working in manufacturing. Another thing they had in common? They were all preventable.

With solid planning and some helpful technology, it’s easy for maintenance teams to avoid health and safety violations while creating a better health and safety program.

What is OSHA?

OSHA is the government-run organization in charge of assuring safe and healthy working conditions for millions of public and private sector employers and workers across the US. They do this by setting and enforcing standards and by providing training, outreach, education and assistance.

What is the purpose of OSHA?

OSHA is responsible for the hefty price tags attached to noncompliance and is the organization that maintenance teams have to impress most often when it comes to health and safety audits.

OSHA regulations, OSHA compliance, and OSHA penalties

The following is a brief rundown of the rules and responsibilities mandated by OSHA and the impact of breaking these regulations.

What are employers responsible for?

Under OSHA law, employers are responsible for providing a safe and healthy workplace for their workers. Employers must provide workers with a hazard-free workplace and must follow all OSHA standards. Employers must find and correct all safety and health problems, first by changing working conditions, like switching to safer chemicals, and then by providing protective equipment.

Besides the potential for accidents, injury, and death, OSHA violations inflicted a heavy toll on the bottom line, costing businesses over $400 million last year.

Other guidelines that employers must follow include:

  • Prominently displaying official OSHA requirements, OSHA citations, and injury and illness data.
  • Informing workers about hazards in a language they can understand through training, labels, alarms, and other methods.
  • Keeping accurate records of work-related injuries and illnesses.
  • Performing tests in the workplace, such as air sampling.
  • Providing the required personal protective equipment at no cost to workers.
  • Not retaliating against workers for using their rights under the law.

These are some examples of the broad policies employers at production facilities need to follow. However, there are many OSHA regulations that apply to specific industries or in certain regions. Some examples of these standards include providing fall protection, ensuring safety in confined spaces, putting guards on dangerous machines, and providing respirators to employees.

What rights and responsibilities do workers have?

Workers also have a responsibility to attend training, ensure they report unsafe work, and follow guidelines set out by employers and OSHA. In addition to their responsibilities, workers also have several rights under OSHA laws, including:

  • The right to file a confidential complaint to have their workplace inspected.
  • The right to receive copies of the results from health and safety tests and monitoring.
  • The right to participate in an OSHA inspection and speak in private with the inspector.
  • The right to file a complaint with OSHA if they have been retaliated against by their employer.
  • The right to file a complaint if punished or retaliated against for acting as a whistleblower.

How are OSHA standards created?

OSHA standards-setting process is a multi-step activity that relies heavily on public engagement. New standards can be recommended either by OSHA itself or through third-party petitions from organizations like the National Institute for Occupational Safety and Health, state and local governments, and labour representatives.

After deciding to move forward with a new standard, OSHA often asks the public for their feedback and insight. After considering all information and testimonies, OSHA develops and issues a final standard that becomes enforceable.

What happens during an OSHA inspection?

When OSHA finds employers who are in violation of the regulations, inspections are initiated without advance notice by compliance officers. Here’s how the on-site inspections usually happen:

  • The compliance officer presents their credentials.
  • They explain why the workplace was selected for inspection and describe the inspection process, including walkaround procedures, employee representation, and employee interviews.
  • The compliance officer and facility representatives walk through the workplace, inspecting for hazards.
  • The compliance officer talks with the employer and employee representatives about their findings.
  • If no hazards or OSHA violations are found, the inspection is over. If an inspector finds violations or serious hazards, they may issue a citation and/or fine. A citation outlines methods that can be used to fix a problem and a deadline for correcting the issue, as well as the date by which the corrective actions must be completed.

What are the fines for OSHA violations?

Fines for non-compliance of OSHA regulations can vary based on the seriousness of the violation and the organization’s record and the industry. However, OSHA has outlined maximum fines, which for 2018 include $13,260 for minor and serious violations and $132,598 for willful or repeat violations.

The most common OSHA violations

Below are the 10 OSHA violations most frequently committed by workplaces in 2018:

OSHA ViolationNumber of violations in 2018
Fall Protection – General Requirements (Standard 1926.501)7,270
Hazard Communication (Standard 1910.200)4,552
Scaffolds – General Requirements (Standard 1926.451)3,336
Respiratory Protection (Standard 1910.200)3,118
Lockout/Tagout (Standard 1910.147)2,944
Ladders (Standard 1926.1053)2,812
Powered Industrial Trucks (Standard 1910.178)2,294
Fall Protection – Training Requirements (Standard 1926.503)1,982
Machine Guarding (Standard 1910.212)1,972
Personal Protective and Lifesaving Equipment – Eye and Face Protection (Standard 1926.95)1,536

How maintenance teams can prevent OSHA violations

Here are a few tools and techniques maintenance teams can use to steer clear of violating some OSHA regulations. Each of these tips can be implemented through maintenance management software, such as a CMMS.

Hazard communication

It’s never easy to tear yourself away from a job when your to-do list is a mile long. Then again, when you don’t make time for health and safety tasks, it can result in a huge fine. Over 4,500 companies faced this exact situation in 2018 after they violating the OSHA’s hazard communication standard by failing to provide proper hazard training and maintain the necessary data sheets.

OSHA is also responsible for the hefty price tags attached to noncompliance, and is the organization maintenance teams have to impress most often when it comes to health and safety audits.

Maintaining records and providing health and safety training is often a hassle, even if it’s extremely important. Having an efficient method for storing employee information can go a long way in saving you time and helping you stay compliant. Create employee profiles for everyone on the maintenance team. On each profile, list the training that person has, the dates they completed training, and the training they still need. Make sure to note deadlines for certification renewals on each profile. Create a notification system so both you and the employee are alerted about any training that is about to expire. Lastly, use these profiles to communicate any hazardous situations or changes in policy to all staff.

Lockout/tagout

Lockout/tagout violations ranked as the fifth-most-common breach of OSHA regulations during 2018, even with it being standard procedure across the maintenance and manufacturing world. Facilities were cited for failing to implement an energy control program and to provide training.

Energy control programs help maintenance staff avoid being injured by the massive amounts of hazardous energy that is often stored by equipment. Although many facilities have an energy control program, they are often not implemented properly.

One of the biggest obstacles to policy implementation is a lack of accessibility. Technicians are extremely busy and are often overwhelmed on a daily basis. If they are working on an asset, need to conduct a lockout/tagout and don’t know the proper procedure, it’s not likely that they will spend valuable time looking for the information. Making an energy control program document available digitally and accessible through a mobile device eliminates this problem, is a factor in the successful implementation and helps facilities avoid a costly OSHA violation.

Fall protection – training and general requirements

Companies were handed over 9,000 fines for inadequate fall protection in 2018, with these violations scoring top spot and eighth place on the OSHA’s list. The most common rules that were broken were failing to provide sufficient training and proper protective equipment.

Training your whole workforce might be the end goal of your fall protection plan, but it might not be realistic in the short term. However, there are a few ways employers can better manage their existing pool of trained maintenance staff to avoid violating OSHA regulations. You must be able to cross-reference work orders with staff who are certified (and who have proof of certification). The best way to do this is through a digital maintenance work order system. This system can tell you who is available and the best person to do the job, so no one is working at heights without the proper training.

Equipment for fall protection often includes harnesses, guardrails, anchors, and other, larger pieces. These items need to be maintained and stored properly. That is why a well-built inventory management system is a must for safety and to avoid OSHA violations. The ability to track where parts are stored, their history of use, and how often they’ve been maintained is crucial. It ensures that workers know where to find the proper protective equipment when they need it and that they know it will be in optimal working condition. Having a digital inventory system makes this information more accessible and creates a more efficient process.

Machine guarding

Machine guarding was another common OSHA violation in 2018, averaging 5.5 infractions per day. Inspectors cited companies for point of operation and for guards that were not attached to machines.

It’s easy to assume this violation can be avoided by simply walking around your facility, installing guards where needed and training staff to always use them when necessary. However, this isn’t a set-it-and-forget-it issue. It requires an ongoing effort to ensure guards are installed and maintained properly. A guard may rust over time, diminishing its effectiveness. An employee may remove a guard for a project and not replace it properly or at all. That is why you and your maintenance team must be diligent about machine guarding.

One way to ensure consistency with machine guarding at your facility is through automated work orders and maintenance triggers. Determining a maintenance trigger for each guard will help you plan an inspection, repair, or replacement well ahead of time. For example, a certain guard may be slated for replacement every three months. These maintenance triggers can then be scheduled using an automated work order system to ensure you’ll be alerted of upcoming maintenance or inspection for machine guards so tasks don’t fall through the cracks and leave you vulnerable to citations or fines.

Personal protective and lifesaving equipment

The last entry on the OSHA’s list of top violations is one that can apply to many maintenance activities and can have a huge impact on safety. There were over 1,500 instances of facilities failing to provide personal protection equipment (PPE) and lifesaving equipment or failing to ensure employees used them in the right situation.

PPE can vary from job to job in a facility. One maintenance task may require an individual to wear hearing protection while another may call for a dust-blocking face mask. It can be difficult for staff to remember what PPE is associated with which job, which means tasks are not always completed in the safest way (or in accordance with OSHA regulations).

Solving this problem can be as easy as attaching a checklist to each maintenance task or asset that outlines the required PPE. Not only will this standardize PPE practices at your facility, but it also reminds the staff what they should be doing. If the checklist is available in a digital format, it is even more accessible to staff, which means that the protocols are more likely to be followed.

Source: https://www.fiixsoftware.com/blog/maintenance-avoid-top-osha-violations/

PTW – Trouble or Safety?

Permits to work will often be found in high-risk industries, but what is their purpose?

A permit to work system is a formal documented system, used to control high-risk activities. They are usually issued by a manager or supervisor and allow a person or group of people to carry out a task, under strict controls.

Permits will authorize certain personnel to carry out high-risk work at a specific time, providing that the procedures detailed in the permit are followed. Permits to work are likely to be required for activities such as electrical works, hot works, excavations, work at height and confined space works.

So how do permits to work ensure safety?

  • A manager or supervisor will give written permission to carry out a task
  • Ensure every aspect of the work is planned
  • Make sure every aspect of the work is checked
  • Communicate health and safety information
  • Provide control procedure in place
  • Return the area to a safe state on completion of the work
  • Give a means of communication and written record

Types of Work Permit:

  • Hot Work Permit – Authorization to perform tasks in conditions that produce sparks, flames, or any other source of ignition.
  • Excavation Permit – Authorization for personnel to mine or dig land to build infrastructure, extract resources, etc.
  • Work-at-Height Permit – Authorization to work on elevated spaces e.g. ladders, scaffolds, Mobile Elevated Work Platforms (MEWP), and other spaces that are elevated.
  • Electrical Isolation Permit – Authorization to work in high voltage zones. Common electrical isolation work is to manage and maintain lockout/tagout systems.
  • Confined Spaces Work Permit – Authorization to perform tasks in a narrow space that is prone to hazards like asphyxiation, fire, toxic atmosphere, etc.

In order for the permit to work and fulfill its purpose, it needs to cover all the legal requirements and strict adherence to the procedures by all workers.

Contractor May Affect Your Safety Performance at Plant!

Why is contractor management important?

Using contractors involves an outside organization that will create risk to the site company. The contractors who are unfamiliar with the facility may create process hazards to the company. Thus companies must recognize and address challenges associated with using contractors; and select contractors based on stringent criteria. Only then can the company ensure safety of all people (onsite and offsite).

Contractor management is a system of controls to ensure that contracted services support safe facility operations. This element addresses the selection, acquisition, use, and monitoring of such contracted services. Systems must be established for qualifying firms based upon not only their technical capabilities, but also their safety programs and safety records.

The boundaries of authority and responsibilities must be clearly defined for any contractor that works at the facility. Periodic monitoring of contractor safety performance and auditing of contractor management systems is required. After completion of the work, evaluation of the safety performance should help to determine whether the contractor can be used again in any future work.

Contractors are not familiar with the facility safety controls and procedures hence the company needs to train them to understand the safety controls and procedures prior to them starting their work. The company must also make contractor to aware that they treat safety seriously and the contractors must adhere to all safety rules, guidelines, procedures, etc. while performing their job. Training must be provided to contractors if they are handling critical tasks that may create major process safety hazards.

Don’t treat contractor management as a petty issue, it can create process safety hazards if it is not well managed.

Steps and Methods to Conduct a Process Hazard Analysis

How to use Process Safety Analysis to the benefit of your process plant?

What is Process Hazard Analysis (PHA)? A PHA is required for any industrial process that makes use of hazardous chemicals. Its purpose is to identify the significance of scenarios (potential causes and consequences) that could result in fires, explosions, chemical spills and the release of toxic chemicals. It focuses on factors that might affect the process (equipment, instrumentation, utilities, human actions (routine and non-routine), and external factors).

Steps in the PHA Process

Methods for Conducting the PHA:

  • What-if Study – for review of an uncomplicated processes;
  • Checklist – for a more complicated process using a checklist;
  • Hazard and Operability Study (HAZOP) – a structured method to analyze possible deviations in design conditions;
  • Failure Mode and Effects Analysis (FMEA) – a systematic study of component failures that could conceivably affect the safety of the operation;
  • Fault Tree Analysis – either a qualitative or a quantitative model of all the undesirable outcomes, that could result from a specific initiating event; or
  • An appropriate equivalent method.

The process hazard analysis is best performed by a team with expertise in engineering and process operations. The PHA team should include:

  • Employees who have experience with and knowledge of the process being evaluated; and
  • Team leader who has knowledgeable in the specific PSM analysis methodology being used in the evaluation.

It is advised that,  at least every five years after the completion of the initial process hazard analysis or whenever there is a change in process, the process hazard analysis must be updated and revalidated by a qualified team to ensure that the hazard analysis is consistent with the current process.

Process Safety – Don’t Wait for A Catastrophe, Manage It!

Process Safety Management

Do you know what is Process Safety Management and why is it important to your process facilities?

Well, Process Safety Management (PSM) is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment (OSHA, U.S.). When applied correctly, process safety management could aid to prevent fires, explosions and the release of hazardous chemicals that could pose a safety risk to workers or the general public.

OSHA has introduced 14 elements of PSM:

Let’s understand briefly and go through each of the 14 elements of PSM!

Employee Involvement

Employee is the human asset of the company and they are also the ones to determine the safety of a plant. Hence employee participation in PSM programs are important. Employee participation is for employees, production, maintenance, and staff to be involved in all aspects of the PSM program at your site, and to have representation in the development, discussion, and eventual solution to issues around the process hazard analysis.

Process Safety Information

According to OSHA’s PSM mandates, “The employer shall complete a compilation of written process safety information before conducting any process safety hazard analysis required by the standard.” It means that all workers should be able to access and understand the technical data regarding the highly-hazardous-chemicals-related risks they face on the job.

Process Hazard Analysis

Process Hazard Analysis requires that engineers and maintenance leaders analyze the consequences of safety failures. This process analysis will be conducted as a team and includes at least one person “who has experience and knowledge specific to the process being evaluated” and is “knowledgeable in the specific process hazard analysis methodology being used.”

Operating Procedures

Startups following a turnaround, and after an emergency shutdown is included in this element. Standard Operating Procedures of these events should be documented and practiced by the operation and maintenance-teams-can-avoid-the-top-osha-violations/” >maintenance team.

Training

Workers who carry out processes involving highly hazardous chemicals need to be well-trained, and their training should have been accomplished through a competent source and be well-documented.

Contractors

Contractors must be well-informed of the hazards they face. Under the PSM National Emphasis Program, “The employer, when electing a contractor, shall obtain and evaluate information regarding the contract employer’s safety performance and programs. The employer shall inform contract employers of the known potential fire, explosion or toxic release hazards related to the contractor’s work and the process.”

Pre-startup Safety Review

OSHA expects employers to perform pre-startup safety reviews for both new and modified facilities even for a change in a single component.

Mechanical Integrity

Periodic, documented inspections are required for several systems, including pressure vessels and storage tanks, piping systems, relief and vent systems and devices, pumps, controls, etc. The inspectors conducting these inspections must not only be officially trained, their testing procedures must follow “recognized and generally accepted good engineering practices,” according to OSHA.

Hot Work Permit

Every employer needs to issue permits to employees and contractors who perform high-temperature work (e.g. welding) near covered processes. They also need to train their personnel to post and file these permits.

Management of Change

Many organizations choose to issue an MOC for every change because there are many details, and questions that maintenance and engineering have to answer satisfactorily to make this a safe process. Prior to any change, the following are considered:

  • The technical basis for the proposed change
  • Impact of change on safety and health
  • Modifications to operating procedures
  • Necessary time period for the change
  • Authorization requirements for the proposed change

Incident Investigation

An investigation is performed into all incidents that result in, or could reasonably have resulted in, a catastrophic release of highly hazardous chemicals (HHC).

Emergency Planning and Response

It requires employers to establish and implement an emergency action plan, including a plan to handle small releases.

Compliance Audits

According to the PSM-NEP, “Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.” It is also a requirement to retain the last two most recent audit reports.

Trade Secrets

Some companies attempted to protect proprietary information by keeping process details from their employees. To enhance worker safety, the “trade secrets” which may affect their health and safety are divulged to the workers.

Now that you have the basic knowledge about the 14 elements of PSM, find out how to manage them!