general plant safety issues dist
TRANSCRIPT
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General Plant Safety Issues
IntroductionThe following section addresses these areas of concern in your facilityand are listed in the order of predominant OSHA violation focus:
Hazard CommunicationEmergency Action Plan/Exits/EgressFire Safety/Eye Washes
Limited/Blocked Access to Disconnect Means
Walking/Working Surfaces/Housekeeping
Electrical Hazards
Hoist Safety
Forklift Safety (PIT)Permit-Required Confined Space
ErgonomicsGeneral Programs/Documentation
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Hazard Communication Purpose
1910.1200(a)(1)
The purpose of this section is to ensure that the hazards of all chemicals produced or
imported are evaluated, and that information concerning their hazards is transmitted
to employers and employees. This transmittal of information is to be accomplished
by means of comprehensive hazard communication programs, which are to include
container labeling and other forms of warning, material safety data sheets andemployee training.
1910.1200(f)(7) Exemption:
The employer is not required to label portable containers into which hazardous chemicals
are transferred from labeled containers, and which are intended only for the immediate use
of the employee who performs the transfer.
The issue that arises when evoking this exemption is when the employees transferring (or
controlling) the material turns away, goes on break or otherwise does not have full control
of the container. Full control of an unlabeled container is very difficult to manage unless it is
truly very small quantities and for immediate use.
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Hazard Communication
ConcernsAreas of concern are:
Lack of numerical/pictorial labeling of individual bottles
Individual containers hand labeled with cryptic information
Unlabeled open 3-5 gallon buckets containing mysterious substance
MSDS signs may mislead employees as to the location of the actual documents
Hazard communication is one of the most often cited violations under OSHA regardless if it
is a State/Federal plan. In 2007 1910.1200 was the #1 cited violation for general industry
at 5931 for a settled value of $1,218,351.00 (CCH, August 2009).
XYZ Foods specific hazard communication program was not reviewed as part of this plant
visit, therefore, gaps in the program are not addressed. Within the scope of this review
container labeling is a issue and observed repeatedly as well as language barriers.Most preferably the numerical category provided using the NFPA 704 or the HMIS system
would enhance the labeling communication as they are numerical /pictorial and easily
identifiable.
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Hazard Communication
1910.1200(f)(9)The employer shall ensure
that labels or other forms
of warning are legible, in
English, and prominently
displayed on the container,
or readily available in the
work area throughout each
work shift. Employers
having employees who
speak other languages may
add the information intheir language to the
material presented, as long
as the information is
presented in English as
well.
MSDS
http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_1200&src_anchor_name=1910.1200(f)(9)http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_1200&src_anchor_name=1910.1200(f)(9) -
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Hazard Communication
Recommendations For MSDS
1. Designation of person(s) responsible for obtaining and maintaining the MSDSs;
2. How such sheets are to be maintained in the workplace (e.g., in notebooks in
the work area(s) or in a computer with terminal access), and how employees can
obtain access to them when they are in their work area during the work shift;
3. Procedures to follow when the MSDS is not received at the time of the first
shipment;
4. For producers, procedures to update the MSDS when new and significant health
information is found; and,
5. Description of alternatives to actual data sheets in the workplace, if used.
1910.1200 Appendix E
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Hazard Communication
Recommendations For MSDS (con)
For any safety and health program, success depends on commitment at
every level of the organization. This is particularly true for hazard
communication, where success requires a change in behavior. This will
only occur if employers understand the program, and are committed to
its success, and if employees are motivated by the people presenting
the information to them.
1910.1200 Appendix E
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Hazardous Communication
1910.1200
NFPA 704 Label HMIS Label
LABEL TYPES
"Hazardous chemical" means any chemical which is a physical hazard or a health hazard.
1910.1200(c)
Container
Labels
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1910.1200(f)(5)The employer shall
ensure that each container of
hazardous chemicals in the workplace
is labeled, tagged or marked with the
following information:
Identity of the hazardous chemical(s)
contained therein; and,
Appropriate hazard warnings, or
alternatively, words, pictures, symbols,
or combination thereof, which provide
at least general information regarding
the hazards of the chemicals, and
which, in conjunction with the other
information immediately available toemployees under the hazard
communication program, will provide
employees with the specific
information regarding the physical
and health hazards of the hazardous
chemical.
Individual Container LabelsMaintenance Room
ADD Proper LABEL
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Individual Container Labels
Maintenance Room
Proper Label Improper Label
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Individual Container Labels
ADD Proper
LABEL
Bakery
1910.1200(f)(5)The employer shall
ensure that each container of
hazardous chemicals in the workplace
is labeled, tagged or marked with the
following information:
Identity of the hazardous chemical(s)
contained therein; and,
Appropriate hazard warnings, or
alternatively, words, pictures, symbols,
or combination thereof, which provide
at least general information regarding
the hazards of the chemicals, and
which, in conjunction with the other
information immediately available to
employees under the hazard
communication program, will provide
employees with the specific
information regarding the physical
and health hazards of the hazardous
chemical.
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Individual Container LabelsAppetizers USDA
Although this appear to be food stuff it is possible for employees to misunderstand the
contend, therefore, it is a good practice to label with material content.
ADD Proper
LABEL
Exemption: 1910.1200(f)(7)
The employer is not required to label portable containers into which hazardous chemicals
are transferred from labeled containers, and which are intended only for the immediate use
of the employee who performs the transfer.
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Individual Container Labels
Zoom Shot
Shells
Although these labels
identify the contents ofthe containerit is not
adequate. The haz com
labeling system must
be uniform and be
readily
identified/recognizedespecially as XYZFoods
has multiple languages
spoken by employees.
It s best to use a
universally recognized
label with pictorialdisplay. This aligns with
1910.1200(f)(9).
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Recommendations For
Individual Containers & Labeling
1. Designation of person(s) responsible for ensuring labeling of
in-plant containers;
2. Designation of person(s) responsible for ensuring labeling of any
shipped containers;
3. Description of labeling system(s) used;4. Description of written alternatives to labeling of in-plant
containers (if used); and,
5. Procedures to review and update label information when
necessary.
1910.1200 Appendix E
Ensure Compliance by:
Consider purchasing a label maker for your hazard communication individual
containers as it will print numerical values for each hazard category and pictorial
icon for the PPE requirement as they help to bridge the language barrier.
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Individual Container Labeling
Post this Guide
Recommendations: utilize NFPA 704 or HMIS labeling and provide labeling stations
strategically place, including this or similar pictorial guide with an audit program and
restocking activities.
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Individual Container Labeling
HMIS Label
Recommendations: utilize NFPA 704 or HMIS labeling and provide labeling stations
strategically place, including this or similar pictorial guide with an audit program and
restocking activities.
Post this Guide
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Individual Container LabelingThis system uses the NFPA
704 label but can be adaptedto HMIS
Holes for mounting2 at the
top and 2 at the bottom
Permanent Marker
Fits in These Slot
Place a stockof labels in
this slot
Price (ea.) $15.39
Brand MASTER
Mfr. Model # S1601
Recommendations: utilize NFPA 704 or HMIS labeling and provide labeling stations
strategically place, including this or similar pictorial guide with an audit program and
restocking activities.
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Emergency Action Plan, Exits & Egress
Emergency action plans (EAP) are required for all business regardless of the size.
1910. 38 was cited as a violation 195 time for a settled value of $78,860.00. The
EAP program was not reviewed as part of this plant visit, however, only three
issues were observed and they were not overt. This is an area of concern due tothe fact that having an issue with exiting a building may lead to a catastrophic
event. Maintenance of exits is a highly cited violation with 1253 issued in 2008 at
a settled value of $565,980.00. This issue is also the primary focus of NFPA Life
Code 101.
Most of the exit doors were appropriately marked. Exceptionin the ammonia
room where the exits were difficult to find due to marking and the poor
lighting.
Additionally several of the interior doors are not identified as Not An Exit.
Purpose of Emergency Action Plan (EAP), exit, & egress is to ensure safe exiting in case
of an evacuation emergency. 1910.34
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EXITS, EGRESS & EMERGENCY ACTION
PLAN (EAP)What is an Egress/Exit?
NFPA 101
A.3.3.161 Means of Egress.
A means of egress
comprises the vertical and
horizontal travel and
includes intervening room
spaces, doorways, hallways,
corridors, passageways,
balconies, ramps, stairs,
elevators, enclosures,
lobbies, escalators,
horizontal exits, courts, andyards.
OSHA 1910.33 Means of Egress
is the way to, through, and
away from and exit.
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EAP, Exits & EgressAn employer who demonstrates
compliance with the exit route
provisions of NFPA 101-2000, the
Life Safety Code, will be deemed to
be in compliance with the
corresponding requirements in
1910.34, 1910.36, and 1910.37.
[39 FR 23502, June 27, 1974, as
amended at 45 FR 60703, Sept. 12,
1980; 53 FR 12121, Apr. 12, 1988;
67 FR 67962, Nov. 7, 2002] CFR
291910.35
Note: 1910.37(a)(1) Exit routes must be kept
free of explosive or highly flammable
furnishings or other decorations.
Well
Identified
Exit
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EAP, Exits & Egress3.3.161* Means of Egress. A continuous and unobstructed way of
travel from any point in a building or structure to a public wayconsisting of three separate and distinct parts:
(1) the exit access,
(2) the exit, and (3) the exit discharge.
4.5.3.2 Unobstructed Egress. In every occupied building or
structure, means of egress from all parts of the building shall be
maintained free and unobstructed. Means of egress shall beaccessible to the extent necessary to ensure reasonable safety
for occupants having impaired mobility.
NFPA 101, Life Code Safety 2009
Exit route means a continuous and unobstructed path of exit travel
from any point within a workplace to a place of safety (including
refuge areas). An exit route consists of three parts: The exit access;
the exit; and, the exit discharge. (An exit route includes all vertical
and horizontal areas along the route.) 1910.34(c)
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EAP, Exits & Egress
1910.37(b)(5) Each
doorway or passage along
an exit access that could be
mistaken for an exit must
be marked "Not an Exit" or
similar designation, or be
identified by a sign
indicating its actual use
(e.g., closet).
Doors may be labeled as Not An Exit or be labeled with the use or purpose of the room
such as closet or janitorial supplies.
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EAP, Exits & EgressAppetizer USDA Affix not An Exit to doors
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EAP, Exits & EgressPackaging
Shells
Label All Doors
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EAP, Exits & Egress
Label All Doors
Ammonia Room
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FIRE SAFETY & EYE WASHES
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Fire Safety/Eye WashesFire Extinguishers
The issues observed are related to the overall employees safety as it relates to OSHA
General Industry standard Subpart L. At XYZ Foods the issues are:
Lack of inspection/testing/maintenance of fire
Lack of documentation of inspection
Fire extinguishes blocked
Eye WashesNFPA/ANSI/OSHA all have various conditions where eyewash (and drench showers)
stations are required and likewise various standards for these safety devices. The
explanation for specifics are not clearly and specifically centrally located. Regardless as
XYZ Foods have eyewashes in the plant they must be maintained and managed.
Fire hazards & eyewash are often cited by OSHA during inspection due to the magnitudeof potential. It is extremely important to align the written program with the plant
practices. For XYZs Foods this is especially true due to the multiple languages spoken by
the employees. Because fire extinguishers are provided there is an assumption of safety
and beyond the OSHA citation issue, having fire extinguishes that are not in readiness
condition, depressurized, or the access blocked could lead to high liability results., This is
highly cited by OSHA and is covered in the NFPA 10 as well as NFPA Life Code 101.
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Fire Extinguishers
NFPA 10 Fire Extinguishers Overall7.1.1 The owner or designated agent or occupant of the property in which the fire
extinguishers are located shall be responsible for inspection, maintenance,
and recharging.
7.1.3 Removing from service for maintenance or recharging shall be replace by a fire
extinguisher suitable for the type hazard being protected and shall be at least
equal rating.
NFPA Specific
Inspection
Examination for obvious damage, corrosion, leakage, or clogged nozzles. NFPA 10 7.2.2.2
Corrective action
When a inspection of any fire extinguisher reveals deficiency in any of the conditions listedin 7.2.2.2 immediate correction action shall be taken. NFPA 10 7.2.3
Removing
Removing from service for maintenance or recharging shall be replace by a fire extinguisher
suitable for the type hazard being protected and shall be at least equal rating. NFPA 101
7.1.3
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Fire Extinguishers & OSHA
1910.157(a)Scope and application. The requirements of this section apply to the placement,
use, maintenance, and testing of portable fire extinguishers provided for the use of
employees. Paragraph (d) of this section does not apply to extinguishers provided for
employee use on the outside of workplace buildings or structures. Where extinguishers are
provided but are not intended for employee use and the employer has an emergency action
plan and a fire prevention plan that meet the requirements of 29 CFR 1910.38 and 29 CFR
1910.39 respectively, then only the requirements of paragraphs (e) and (f) of this section
apply.
1910.157(b)(2) Where the employer has an emergency action plan meeting the requirements
of 1910.38 which designates certain employees to be the only employees authorized to use
the available portable fire extinguishers, and which requires all other employees in the fire
area to immediately evacuate the affected work area upon the sounding of the fire alarm, the
employer is exempt from the distribution requirements in paragraph (d) of this section.
OSHA allows a building without fire extinguishers as stated below if the EAP is to
evacuate the building. However, all insurance carriers and local/state fire agencies
require them in building where visitors/employees o occupants are present. OSHA goes
on to state that if fire extinguishers are provided employers must train designated
employees to use them.
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Fire Extinguisher
Where required by the provisions of
another section ofthis Code,
portable fire extinguishers shall be
installed, inspected, and maintained
in accordance with NFPA10, Standard
for Portable
Fire Extinguishers. NFPA 101 9.7.4.1*
Unsuitable Fire Extinguisher
Discharging Unit
This condition was not simply a one-time
occurrence, it was the general overall
condition.
1910.157(c)(4) The employer shall assure
that portable fire extinguishers are
maintained in a fully charged and
operable condition and kept in their
designated places at all times except
during use.
1910.157(e)(2) Portable extinguishers or
hose used in lieu thereof underparagraph (d)(3) of this section shall be
visually inspected monthly.
(1910.157(d)(3) standpipe replacing fire
extinguishers).
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Fire ExtinguisherUnsuitable Fire Extinguisher
Overcharging Unit
1910.157(c)(4) The employer shall
assure that portable fire
extinguishers are maintained in a
fully charged and operable
condition and kept in their
designated places at all times
except during use.
1910.157(e)(2) Portableextinguishers or hose used in lieu
thereof under paragraph (d)(3) of
this section shall be visually
inspected monthly.
(1910.157(d)(3) standpipe
replacing fire extinguishers).
Where required by the provisions of another section ofthis Code, portable
fire extinguishers shall be installed, inspected, and maintained in
accordance with NFPA10, Standard for Portable
Fire Extinguishers. NFPA 101 9.7.4.1*
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Fire Extinguisher
BLOCKED
The employer shall provide portable fireextinguishers and shall mount, locate and
identify them so that they are readily
accessible to employees without subjecting
the employees to possible injury. OSHA
1910.157(c)(1)
Where required by the provisions of
another section ofthis Code, portable fire
extinguishers shall be installed, inspected,
and maintained in accordance with
NFPA10, Standard for Portable
Fire Extinguishers. NFPA 101 9.7.4.1*
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Fire Extinguishers Monthly Inspection
1910.157(e)(2) Portableextinguishers or hose used in
lieu thereof under paragraph
(d)(3) of this section shall be
visually inspected monthly.
(1910.157(d)(3) standpipe
replacing fire extinguishers).
InspectMonthly &
Sign-off
This condition was not simply a one-time
occurrence, it was the general overall
condition.
Where required by the provisions of
another section ofthis Code,
portable fire extinguishers shall be
installed, inspected, and maintained
in accordance with NFPA10, Standardfor Portable
Fire Extinguishers. NFPA 101 9.7.4.1*
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Eye Washes
Where the eyes or body of any
person may be exposed to injurious
corrosive materials, suitable
facilities for quick drenching or
flushing of the eyes and body shallbe provided within the work area for
immediate emergency use. OSHA
1910.151(c)
Attach tags, inspect & sign-
off monthly
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Limited/Blocked Access to Disconnect
Means
Disconnect means & electrical panel boxes must be accessible to employees in
cases of emergency shut-down & lockout/tag out procedures. During our
assessment it was observed as a general condition where material was
stored/stacked in front and in close proximity of disconnect means. In bakery area
there were several electrical boxes where yellow painted floor marked the zone ofnot storage and this was generally observed.
In one case the disconnect means was in the off position with no tag (no apparent
LOTO procedure). This is displayed in the first slide following. In & of itself this is
not a violation however, it does communicate misinformation as to the status of
the machine/equipment or device it supplies. It is advisable to communicate with
tags the status of disconnect means or electrical equipment in repair or out-of-service.
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Limited/Blocked Access to Disconnect
Means Switch in off-positionwithout a locksendsmixed message to
employees including the
disposition of the switch
& machine/device/
operation associated
with it.1910.147(c)(7)(i) The
employer shall provide
training to ensure that the
purpose and function of the
energy control program are
understood by employees and
that the knowledge and skills
required for the safe
application, usage, and
removal of the energy controls
are acquired by employees.
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Limited/Blocked Access to Disconnect
Means
1910.305(j)(4)(v) The
disconnecting means
shall be readily
accessible. If more
than one disconnect isprovided for the same
equipment, only one
need be readily
accessible.
BLOCKED
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Limited/Blocked Access to Disconnect
Means
This raised disconnect makes
it impossible for employees to
shut-down its associated
machine/equipment/device
without the aid of a ladder.
Shells
Zoom Angle
BLOCKED
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Limited/Blocked Access to Disconnect
Means
Dock Area
BLOCKED
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Limited/Blocked Access to Disconnect
Means
Various Locations
BLOCKED
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Limited/Blocked Access to Disconnect
Means
BLOCKED
Various Locations
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Limited/Blocked Access to Disconnect
Means
BLOCKED
Various Locations
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Limited/Blocked Access to Disconnect
Means
BLOCKED
Various Locations
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Walking Working Surfaces &
Housekeeping
7.5.1.1.1 Where exits are not immediately accessible from an open floor area,continuous passageways, aisles, or corridors leading directly to every exit shall be
maintained and shall be arranged to provide access for each occupant to not less than
two exits by separate ways of travel, unless otherwise provided in 7.5.1.1.3 and
7.5.1.1.4. NFPA 101
7.1.8 Elements of the means of egress that might require
protection with guards include stairs, landings, escalators, moving walks, balconies,corridors, passageways, floor or roof openings, ramps, aisles, porches, and
mezzanines. NFPA 101
Generally the walking working surfaces including housekeeping were acceptable for thetype of operation at XYZs Foods. There were only a few issues under this standard in the
following slides. Most areas were clean & dry.
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Walking Working Surfaces
Aisle Accessway. The initial
portion of an exit accessthat leads to an aisle.
NFPA 101 3.3.11*
A.7.1.8 Elements of the means of egress
that might requireprotection with guards
include stairs, landings, escalators, moving
walks, balconies, corridors, passageways,
floor or roof openings, ramps, aisles,
porches, and mezzanines. NFPA Life Code
101-2009
Add handrails to this side descending to
ensure ease of transition.
1910.23(d)(1)Every flight of stairs having four or more risers
shall be equipped with standard stair railings
or standard handrails as specified in
paragraphs (d)(1)(i) through (v) of this section,
the width of the stair to be measured clear of
all obstructions
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Electrical Hazards
The areas of concern for the electrical hazards are:
Strain relief issues where colored wire is exposed and present a potential shock or
electrocution
Minimal observation of knock-outs missing
One issue of live receptacles/light fixtures were observed
Electrical panel access was limited (addressed in disconnect means).Need for an Arc Flash Analysis
The overall issue of electrical hazards were minimal at XYZs Foods. These issues
will need to be addressed as quickly as possible.
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Electrical HazardsFittings. Connectors used to connect lengths of cable in a run
shall be of a type that lock firmly together. Provisions shall be
made to prevent opening or closing these connectors whileenergized. Strain relief shall be provided at connections and
terminations. OSHA 1910.305(h)(6)
Allneed to ensure
strain relief at
connection point
Various Locations
Acceptable spool:
Unacceptable
transition (no
spool) from source
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Electrical KnockoutsRepair with
Approved Parts
Unused openings protected.
NEC 2008 Article 110.12(A)
Listed (approved parts) for repair
NEC 2008 Article 110.3(B) Listed (approved parts) for
repairs OSHA 1910.303(b)(2)
Tighten Bushing
Fittings. Connectors used to
connect lengths of cable in a
run shall be of a type thatlock firmly together.
Provisions shall be made to
prevent opening or closing
these connectors while
energized. Strain relief shall
be provided at connections
and terminations. OSHA1910.305(h)(6)
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Electrical HazardsRepair with
Approved Parts
XYZs Area
Listed (approved parts) for repair
NEC 2008 Article 110.3(B)
Unused openings protected.
NEC 2008 Article 110.12(A)
Listed (approved parts) for
repairs OSHA 1910.303(b)(2)
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Electrical HazardsRepair with
Approved Parts
Listed (approved parts) for repair
NEC 2008 Article 110.3(B)
Unused openings protected.
NEC 2008 Article 110.12(A)
Listed (approved parts) for
repairs OSHA 1910.303(b)(2)
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Electrical Hazards
Flexible cords and cables shall be
approved for conditions of use and
location. OSHA1910.305(g)(1)(i)
Care should be taken asnot to use flexible cords
(extension cords) as
permanent wiring.
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Electrical Hazards
Avoid pinch points for
electrical cords
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Electrical Hazards
Arc Flash Analysis needs to
include the user (or at the
box) warning signs that
identify the flash hazard level
and required PPE installed on
every electrical panel.
Consider an Arc FlashAnalysis for the entire
facility
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Hoist Safety
Hoist must be treated as cranes for use, inspection, maintenance, and care. To
do less begs accidents. The major issues for the hoists are:
Lack of disconnect readily accessible & labeled as such
Pendent electrical cables wrapped around hoist hook
Documentation for frequent and periodic inspection (must be compiled &available)
Annual inspection of the hoist by a qualified (or third party) inspector &
documented
Hoist capacity not clearly visible from the floor
Suspended load unattended is a serious violation
This hoist issue is another opportunity for systematic correction. The event of anincident with a hoist is significant due to the load configuration and frequency
of use.
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Hoist DisconnectFollowing the application of lockout or tagout
devices to energy isolating devices, all potentiallyhazardous stored or residual energy shall be
relieved, disconnected, restrained, and otherwise
rendered safe. OSHA 1910.147(d)(5)(i)
At the beginning of each operator's
shift, the upper limit switch of eachhoist shall be tried out under no
load. Extreme care shall be
exercised; the block shall be "inched"
into the limit or run in at slow speed.
If the switch does not operate
properly, the appointed person shallbe immediately notified.
1910.179(n)(4)(i)
Locate a
Disconnect
Means
Ensure Periodic
& Frequent
Inspections
(Document)The employer shall insure that the operator
does not leave his position at the controls
while the load is suspended.
1910.179(n)(3)(x)
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Hoist Safety
Electrical pendent cord
running through the hook. This
practice could cause the
electrical cord to be damaged
and cause a shock or
electrocution if adverse
conditions are present.
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Forklift Safety
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Forklift Safety1910.178(a)(5) If the truck is
equipped with front-endattachments other than factory
installed attachments, the user
shall request that the truck be
marked to identify the
attachments and show the
approximate weight of the truckand attachment combination at
maximum elevation with load
laterally centered.
Note: it is very important toensure positive connection
when using a personnel
working platform
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Permit-Required Confined Space
Permit-Required Confined Space (PRCS)
requires:
A written program
Space assessment
Space labeling
Training for entryincluding emergency rescue &
recovery
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Hazardous Material
Caps should be replace on stored cylinders.
This is more predominant in construction
1926 rather than 1910 general industry. It is
simply a good practice.
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Rotating Shafts
Projecting shaft ends. 1910.219(c)(4)Projecting shaft ends shall present a
smooth edge and end and shall not
project more than one-half the diameter
of the shaft unless guarded by non-
rotating caps or safety sleeves.
1910.219(c)(4)(i)
Rotating shaft protrusion hazard
Cover or cut-off shaft ends
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Rotating Shafts
Rotating shaft
protrusion hazard
Cover or cut-off
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ErgonomicsAlthough OSHA does not have a
specific standard that horizontally
addressed ergonomics every
citation is accompanied with a letter
that specifically and clearly
identifies ergonomics as a
significant safety factor. The OSHA
suggestion for ergonomics is based
on systematic change throughout
your plant. Some suggestions are:
Using mechanical devices where
possible such as hoist, lift tables,
caddies, & roll cartsUsing rotation
Performing stretching exercises
Health programs that emphasize
health lifestyles
Combustible Dust/Process Safety
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Combustible Dust/Process Safety
Management
Combustible Dust Publication Date: 03/09/2010 Publication Type: Meeting
Fed Register #: 75:10739-10740 Standard Number: 1910 Title: Combustible
Dust [Federal Register: March 9, 2010 (Volume 75, Number 45)] [Proposed
Rules] [Page 10739-10740] From the Federal Register Online via GPO Access[wais.access.gpo.gov] [DOCID:fr09mr10-24].
Ammonia Refrigerant Mechanical Refrigeration and Air-Conditioning Installations
Aboard Ship. ANSI/ASHRAE 26-1996, (1996). Provides the minimum general
requirements for the design, construction, installation, operation, inspection,
and maintenance of mechanical refrigeration and air-conditioning equipment
aboard ships to permit the safe, efficient, and reliable operation of such systems.
Flour is classified as a combustible dust and requires potential critical incident
management
Ammonia is classified as a hazardous substance and as such must be managed with the
Process Management System under 1910.119
Purpose. This section contains requirements for preventing or minimizing
the consequences of catastrophic releases of toxic, reactive, flammable, or
explosive chemicals. These releases may result in toxic, fire or explosionhazards. 1910.119 Process Management Systems
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RecommendationOverall your plant is in fairly good condition. The food industry typically have
tremendous housekeeping hazards. Areas that need addressed are listed belowand are listed in the order of typical increased violation dollars of fines:
Hazard Communication
Emergency Action Plan/Exits/Egress
Fire Safety/Eye Washes
Limited/Blocked Access to Disconnect MeansWalking/Working Surfaces/Housekeeping
Electrical Hazards
Hoist Safety
Forklift Safety (PIT)
Permit-Required Confined Space
Ergonomics
General Programs/Documentation
General Programs/Documentation/
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General Programs/Documentation/
Recommendation
Each of the headings were addressed as if an OSHA inspection was conducting
an inspection. Hazard communication is the most often cited issue, followed by
exit/egress, then fire safety. It is noteworthy to clarify that housekeeping is the
first view an inspector sees in the plant, however, this is after the initial review
of documentation including all programs.
The focus of an OSHA inspection is dictated by the reason of the visit butCompliance Officers will certainly look at the programs first. Once the
programs, and of course, the recordkeeping is reviewed their motivation is to
discover the obvious and to look deeper into the disconnects. Disconnect here
is defined as the gaps between the written program, the practices and what
the Compliance Officer observes. Alignment is key. Align your written programs
to your practices, and your employees behavior. Your most difficult task is todiscover these gaps.