Are You Ready For The New Year?

As we enter 2019, I am shocked after visiting many large manufacturing companies in 2018 and while conducting machine guarding audits and training, that I find that most of these very large and well-known companies have still failed to protect their workers' safety by safeguarding their machines. Many of these companies have been in operation before OSHA became law in 1970. Many of these companies have formal safety & health professionals and are paid a good salary to find these hazards and bring them to management to have them corrected but yet they walk past these obvious, serious hazards.

I even had one large candy manufacturer whose brand name is well known tell me that they did not have the money to correct over 650 machines, which have potential serious amputation hazards. Yet on their website, they state, “Free cash flow increased by 52%, from CHF 1.9 billion to CHF 2.9 billion.” So why could they not protect their workers from being injured, and they also state that they only average 31 machine amputations per year? Maybe it is cheaper to pay for the employees’ injury and replace the employee than it is to follow the OSHA regulations and correct their safety & health hazards.

Some of these companies were also OSHA VPP companies, where all hazards must be abated, but in many cases, unless there is a serious injury, OSHA does not come into that place of employment.

It may be true if you visit the OSHA website and conduct an establishment search
https://www.osha.gov/pls/imis/establishment.html
that you find OSHA has a high noncompliance vs citation ratio. Most of their compliance officers are, in my opinion, not very well trained to recognize these hazards until they are called in to conduct an investigation, where an employee received a serious injury or worse, an amputation.

Top 10 OSHA Violations for 2018

So, as we enter the year 2019, watch out for these top 10 OSHA violations.

The Occupational Safety and Health Administration (OSHA) released its preliminary top 10 violations for 2018 in late October at the 2018 National Safety Council Congress & Expo. These standards were the most frequently cited during OSHA’s fiscal year that ended September 30. According to OSHA, the list serves to “increase awareness of these standards so employers can take steps to find and fix the hazards to prevent injury or illness.”

Fall protection has topped the list of most-cited OSHA violations for eight years in a row, and many of the other standards continue to be in the top 10 year after year. The only new item in 2018 is eye and face protection at number 10.

Here’s the full list:

■ Fall protection – general requirements
■ Hazard communication
■ Scaffolding
■ Respiratory protection
■ Lockout/tagout
■ Ladders
■ Powered industrial trucks
■ Fall protection – training requirements
■ Machine guarding
■ Eye and face protection

While reviewing the list, it is important to remain aware that the Federal Occupational Safety & Health Administration (OSHA) is a small agency. When tallied up to include its state partners, OSHA only has 2,100 inspectors who are responsible for the health and safety of 130 million American workers, employed at more than 8 million work sites. This translates to about one compliance officer for every 59,000 workers.

As a result, some serious injuries are not reported, and thousands of potential violations go without citation or fines. In fact, numerous studies have shown that government counts of occupational injury are underestimated by as much as 50 percent. Employers are required to record all injuries meeting the OSHA’s ‘recordable injury’ criteria (except minor first-aid cases) on the OSHA 300 Log, and those meeting the ‘reportable’ criteria are to be reported to OSHA immediately, or within 24 hours of occurrence, as per the criteria defined in 29 CFR 1904. But it doesn’t mean all of them do.

Machine (Un)Safeguarding in Top 10 Violations

The absence of required machine safeguarding remains a perennial issue of OSHA’s Top 10 Most Cited Violations, and 2017 was no exception. It was named number eight on the list with a total of 1,933 violations. These violations refer to OSHA 1910.212 for failing to have machines and equipment adequately guarded.

Any machine part, function, or process that might cause injury should be safeguarded. When the operation of a machine may result in a contact injury to the operator or others in the area, the hazard should be removed or controlled.

A lack of machine safeguarding also held the dubious distinction of making the list of OSHA’s ten largest monetary penalties for the year, not once but four times. In fact, the largest proposed monetary penalty, a staggering $2.6 million (USD), arose from an incident where a worker was crushed to death while clearing a sensor fault in a robotic conveyor belt. OSHA alleges that the company failed to use energy control procedures to prevent robotic machinery from starting during maintenance.

The manufacturer was also cited for exposing employees to crushing and amputation hazards as a result of improper machine guarding, plus failing to provide safety locks to isolate hazardous energy.

Despite these headline fines, the repercussions for employers putting workers in harm’s way remain small under the 1970 Occupational Safety and Health Act. The average federal fine for a serious workplace safety violation was $2,402 in the fiscal year 2016, according to the most recent report by the AFL-CIO. And the median penalty for killing a worker was $6,500.

According to the most recent Bureau of Labor Statistics data, manufacturing plants reported approximately 2,000 accidents that led to workers suffering crushed fingers or hands, or having a limb amputated in machine-related accidents. The rate of amputations in manufacturing was more than twice as much as that of all private industry. The bulk of these accidents occurred while removing jammed objects from a machine, cleaning or repairing the machine, or performing basic maintenance. These injuries were all largely preventable by following basic machine safeguarding precautions.

Rockford Systems is committed to helping organizations reduce injuries and fatalities due to a lack of or non-compliant machine safeguarding. By creating a culture of safety in the workplace, Rockford Systems can help plant managers significantly reduce the number of on-the-job injuries and fatalities that occur annually, plus guard against hefty fines, lost production, and increased insurance premiums.

Where Do We Begin?

Training and Education

Ignorantia juris non excusat (“ignorance of the law excuses not”). Recognizing that education is key to safety, Podojil & Associates, Inc. has offered its Machine Safeguarding Seminars for more than four decades. The International Association of Safety, Health & Environmental Professionals (IASHEP) www.iashep.org also offers both Certified Machine Safeguarding Specialist classroom training and online education for these subjects.

Assessments

If your organization is interested in safeguarding solutions, consider a Machine Risk Assessment or Machine Safeguarding Assessment as the critical first step in any machine guarding process, as outlined in ANSI B11.

Step 1 – Provide Machine List

To get started, please provide Podojil & Associates, Inc. a list of all machines (manufacturer, model number, serial number, and machine description of each machine) to be assessed. This machine list is needed to determine the estimated resource requirement for the onsite audit. Upon receipt of your machine list, an Assessment Proposal will be provided, generally within 24 hours of receipt.

Step 2 – Schedule Onsite Visit

During the assessment, a machine safeguarding specialist will visit your site and conduct a complete audit of all machines identified on the list and evaluate their compliance in five guarding areas (Safeguards, Controls, Disconnects, Starters, and Covers). The assessment is based on OSHA 1910.212, ANSI B11, ANSI/RIA R15.06-2012, and NFPA 79.

Step 3 – Receive Compliance Report and Proposal

Upon completion of the assessment, a Compliance Report and Safeguarding Project Proposal will be provided to identify where each machine is, or is not, in compliance. Where not in compliance, guarding solutions will be suggested along with associated costs and timeframes.

We look forward to assisting your organization with its safeguarding needs. A team member will call you within 24 hours to further discuss your needs and applications.

Please contact John F. (Jack) Podojil at johnpodojil@msn.com or call 1-612-801-1032 (direct) to get started on an assessment today.

Are You Looking for the Right Machine Safeguards?

If you are looking for Machine Safeguarding Products, please visit our My Shop page located on our website at www.podojilconsulting.com. We have machine guarding solutions for drill presses, grinders, lathes, milling machines, press brakes, power presses, radial arm drills, riveters and welders, robots, sanders, saws, vertical lathes, and much more.

Should you have any questions on Machine Safeguarding, remember we have been safeguarding machinery for over 40 years. We believe we are one of the oldest and well-established safety, health & environmental consulting companies in the United States and worldwide.