Tuesday, March 25, 2014

Be Prepared! OSHA to Impose New Federal Rules

Currently in the U.S. there are 34 States that have some regulatory policies with regards to implementing an IIPP (Injury and Illness Prevention Program). A few are mandatory and many others are voluntary in varying degrees. For example, California is a mandatory State and requires a written plan. Depending on certain criteria, the minimum requirements mandate: 
  • The plan be written
  • A specific individual must be identified as a person with the authority to implement the plan
  • The employer must have procedures to evaluate work place hazards (see last month's blog)
  • New employees must show evidence of training
  • All hazardous exposures must be addressed
  • The employer must perform periodic inspections to identify unsafe conditions or work practices

These are just a partial list of the standards imposed by the law in California.

The reason I am bringing this to the attention of the rest of the country is to alert Employers that OSHA has been working on I2P2(Injury and Illness Prevention Rule). This is a new rule being proposed and is scheduled to be released by this September 2014. While we all know that it will take some time to roll this out, it will be effective sooner than later. Assistant Secretary of Labor for OSHA, Dr. David Michaels, has said this is his top rulemaking priority!

The basics of this new standard will be to mandate every workplace to:
  • Provide a comprehensive hazard assessment survey
  • Employers must design a written program to evaluate all hazardous exposures identified and provide periodical reviews of how the plan is minimizing these hazards as well as the risk of injuries to employee. 
  • Employers are also being required to have regular safety meetings with educational materials and training.
Currently, there isn't any federal requirement to perform these hazard assessments, except in certain situations where employees are exposed to unusually dangerous circumstances. One such example would be exposure to some chemicals.

OSHA has done a great deal of research on this topic and see this as a real simple solution with proven principles that will keep millions of Americans safer. The expectation is that implementing this rule will significantly decrease the incidences of workplace injuries and illnesses which in turn will equate to substantial reductions in costs.

The bottom line is that now is the time to get ahead of this and start developing a hazard assessment plan right away. Using last month's blog is a good way to start. Also, there are several websites with examples of programs that are being used now. Identify who your champion will be to administer and be responsible for this and get going!

A Safe Wash Protects People and Profits!
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Wednesday, February 5, 2014

What is a Crushed Foot Worth?

July 16, 2013, a car wash worker's foot was crushed by a conveyor! This can happen at any conveyorized wash. Does your facility have the detailed safety and training policies ready? 

Developing a system to identify hazards in the workplace along with corrective actions is paramount to keeping your employees safe. Early recognition will help to avoid employee injuries and damage to equipment.

The use of personal protection equipment is an example of one practice that is often the first solution to provide the employee with protection in the performance of their work; however, it should be the last resort. There are generally two other options available for preventing or controlling dangerous conditions. They are engineering the exposure out of the job or invoking administrative procedures to minimize or eliminate the condition. Before you can successfully decide which options will work best,  employers should perform what's known as a job hazard analysis (JHA).  This method will determine existing and/or potential  hazards of a specific job so that management can first evaluate which of these policies will be more effective.

Administrative controls would be rules, procedures or standards that prevent or limit  exposure to a specific hazard. This is more about the employee. Engineering controls would be, to the extent possible,  modifications to the actual job process or equipment  that would reduce or eliminate the hazardous condition. This is about changing the environment  making the potential of injury to an employee less likely.

Examples of Engineering controls would be:
  • proper use of transfer pumps to fill secondary containers
  • eliminate use of highly corrosive chemicals and replace with less corrosive solutions
  • add drainage for water runoff
  • add gutters to re-direct water from walking paths used by customers and workers
  • proper preventive maintenance on equipment, walkways and driveways
  • ensuring all equipment with active belts have guards
  • Using proper slip resistant footwear
Some examples of administrative controls  would be:
  • designing and completing a hazard assessment form.
  • specific training  for each task  identified.
  • use accident investigation as a tool to prevent future incidents
  • create a simple process for reporting accidents
  • utilize a daily inspection checklist
  • utilize an open and closing checklist
  • utilize a maintenance log
  • learn from recording and reviewing near misses
  • use proper personal protection equipment
One of the most effective ways to complete this is to conduct a walk-through survey of all work areas and duties. The idea is to list all of the activities associated with each job along with the hazards these tasks present. This can be done by one or more persons who have the responsibility  to document  the results. It is best to include staff that are experienced in each area observed.

The JHA form can be created by your team or search on line for some examples like below. 
This document uses a simple format that breaks down the analysis into three sections, the Steps, Potential Hazard Identification, and the suggested Corrective Action. The Steps are the specific tasks associated with the completion of the operation,  the hazards are the potential or existing dangers associated with the job function and finally the last column is the suggested actions to eliminate or minimize the likelihood of injury or property damage accidents.

In the final step, pretend the team is an investigator interviewing witnesses. The following are some questions that might be posed:
  • What can go wrong?
  • What are the consequences?
  • How could it arise?
  • Are there any contributing factors?
  • How likely is it that something may go wrong?
Once you establish your answers, you can begin to develop your plan to solve the issue identified. Some examples of solutions might be:
  • Can the job be performed in another way?
  • Can you make physical changes to the job?
  • Does the job have to be performed?
As always, ideas no matter how good they may be, are meaningless unless they are put into action.  Conducting  an on-site job hazard assessment, can be the difference between a  serious incident  and an accident that doesn't happen.  Get your committee together  and begin using this  important  tool  before it's too late.

A safe wash protects people and profits!