ENFORCEMENT PRACTICES FOR 

EMPLOYEES  

OSHA defines personal protective equipment as equipment worn to minimize exposure to serious workplace injuries and illnesses. These injuries and illnesses may result from contact with chemical, radiological, physical, electrical, mechanical, or other workplace hazards. Personal protective equipment may include items such as gloves, safety glasses and shoes, earplugs, etc.

With that said, as the saying goes, "you can lead the horse to water, but you can't make him drink" So, the question is, you can provide the items needed to protect the employee, but how do you make them use it? OSHA requires more than availability.

There was an interesting article in Safety/NewsAlert titled "Is it enough to provide safety gear, or do you have to make 'em use it"? Article Link Even though this pertained to a workers compensation case, it raises a good question that I believe every operator should ask themselves. What do I do to promote the use of the devices that will keep my employees safe?

 The following are some ideas that should be part of your list:

• Are employees held accountable for not using protective equipment? How severe should the punishment be? Termination?
• How easy do you make it to find the equipment you want them to use? Are they in a properly labeled container in close proximity of the hazard?
  

  
• Do you train the employees to understand the risks of not using the protection and show them how and when to use it?
• Do you have written policies regarding the company's expectation for using the safety equipment?
• Is the equipment clean and comfortable to use?
• Do you have a maintenance plan to keep the equipment in good working condition?
• Did you assign a person to monitor a personal protection program? Are you aware of how effective it is?
• Do you use signage to warn employees of the hazards and advise them what equipment to use? Are the signs readable and in the proper language?
  

  

  
  
• Do you encourage employees to report unsafe conditions that would require protection equipment? (Front line eyes & ears)

Car wash tunnels and especially equipment rooms are usually the areas that pose the most serious threats to your employee's well-being. This makes the use of personal protection equipment by your employee one of the most important aspects of any safety program. At a minimum, these questions should become a checklist along with any additional ideas you may have to engage the staff to use these devices.

Keep in mind, as employers, there are at least two reasons compliance is critical to your business. First, if an employee is hurt and depending on the severity of an injury, OSHA may elect to levy fines for what they may consider non-compliance with the intent of the regulation. Secondly, even more importantly, an injured worker will cost your company a great deal of time and money. Begin today!

For additional information on personal protection equipment, please visit the following links to car wash safety 101.
Link 1
Link 2

Let us know what questions you would add to our list.

Remember, a safe wash protects people and profits!






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!