Have You Recently Conducted Your Required Safety & Health Program Audits?

In every Safety Solutions news article that I write for The Plastics Distributors and Fabrication Magazine, I write about current issues that have important information for our readers, especially for employers in the plastic distribution and fabrication industry.

The first thing that I always find when visiting a client’s worksite to conduct a mock OSHA safety & health audit is this: although the employer has a formal and written safety & health manual, I find that the owners, managers, supervisors, and especially the employees have not read the information that is in this important document. Or worse, in over 90% of the sites that I have visited or conducted expert witness work for, trying to defend my client, I found that nobody has remembered what that formal and written safety & health manual contained.

I also always find the following unsafe conditions:

■ Employees have not been properly trained, or the employer is not enforcing the information that is mandated in their own safety & health written program or OSHA standards.
■ Machines are not properly safeguarded, or the employees are not using the machine guards that are on the machines.
■ Management is not ensuring that employees are following OSHA-mandated lockout & tryout procedures. In 80% of my audits, the employer has failed to follow OSHA 29 CFR 1910.147 LOTO standards by conducting at least annually their required LOTO periodic audit.
■ Management is not ensuring that chemicals are properly labeled, and even worse, employers are allowing their employees to eat and drink on the factory floor.
■ Employers are not testing their eye wash and showers weekly, and when I ask for the testing records, the client usually does not have them.
■ Fire extinguishers are not being inspected monthly.
■ Employers have not properly trained their forklift operators and have not recertified them at least every three years, and by the way, most operators have never been trained in the forklift owners'/operators' manuals.

Recent OSHA Enforcement Examples

Well, the year is 2018, and all employers should have had their programs and training in place since 1971. OSHA enforcement is on the rise, and penalties for employers who do not follow the regulations are now higher. Here is some information on just two of the latest plastic manufacturers that OSHA has recently visited:

PATERSON, NJ — After an investigation by the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA), a New Jersey plastics manufacturer's facility has been cited for exposing employees to safety and health hazards at its Paterson, New Jersey, facility. OSHA proposed penalties of $435,679.

Do you have that kind of money to pay for citations for not following OSHA rules?

OSHA inspected the plastics manufacturer on Oct. 2, 2017, in response to a complaint alleging unsafe workplace hazards and imminent danger conditions from blocked emergency exits. A health inspection was also conducted on Oct. 11, 2017, after the inspector’s initial readings indicated employee exposure to excessive noise levels.

OSHA cited the employer for failing to administer a hearing conservation program; exposing employees to amputations, electric shock, and burns; allowing employees to use equipment without proper guarding; failing to control hazardous energy; and failing to train powered industrial truck operators.

The company has 15 business days from receipt of its citations and penalties to comply, request an informal conference with OSHA’s area director, or contest the findings before the independent Occupational Safety and Health Review Commission.

Here is one more example:

BELLEVUE, OH — The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) cited a Bellevue-based plastics company for multiple safety violations after an inspection found employees exposed to fall, machine, and electrical hazards. OSHA proposed penalties of $261,454.

OSHA investigators determined that this employer, which operates as a Plastic Services company, exposed its employees to crush injuries, burns, and fall hazards while they conducted maintenance on plastic injection molding presses. Inspectors cited the employer for failing to ensure employees had adequate personal protective equipment and clothing, and for permitting the use of damaged electrical devices.

“Using proper safety controls and removing damaged devices from service can protect employees from exposure to known hazards in the workplace,” said Kim Nelson, OSHA Toledo Area Office Director.

Final Thoughts

Each of these citations that these plastic manufacturers received could have easily been eliminated or complied with. All of these items have also been written about in our other Safety Solutions magazine articles. We rarely hear from our readers, and I know that we can help you and your company.

Should you need an OSHA mock inspection, Podojil & Associates, Inc., which has over 45 years of direct OSHA experience, can conduct an OSHA Mock Inspection of your facilities at an affordable price.

As always, if you have questions on OSHA standards, you are always welcome to email me at johnpodojil@msn.com or call me.